OPINION
WILBUR, Judge:
Respondent has determined deficiencies in petitioner's income tax for the taxable years 1965 and 1966 of $3,735,081.11 and $7,622,261.09. In its petition for redetermination, petitioner alleged numerous errors on the part of respondent, including the disallowance of consolidated net operating losses of $16,981,402, for petitioner's taxable year 1968 and of $62,354,518, for petitioner's taxable year 1969. Respondent's answer...
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