OPINION
SIMPSON, Judge:
The respondent determined deficiencies of $539,369.69 for 1964, $346,408.59 for 1965, and $308,353.34 for 1966 in the Federal income tax of the petitioner. The issues in this case have been severed, and the only issue to be decided herein is whether the petitioner, which adopted a class life for computing its depreciation deduction in accordance with Rev. Proc. 62-21, 1962-2 C.B. 418, as amended by Rev. Proc. 65-13, 1965-1...
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