COHEN, Judge:
In statutory notices of deficiency dated December 23, 1980, in docket No. 2014-81, and April 2, 1982, in docket No. 8056-82, respondent determined deficiencies in petitioner's Federal income taxes as follows:
Docket No. TYE Dec. 31— Deficiency 2014-81 .......... 1972 $46,678.05 1974 227,555.41 1975 96,539.30 ...
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