Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined the following deficiencies in the petitioner's Federal income taxes:
Taxable Year Ending Deficiency Sept. 30, 1966 ........ $ 58,737.95 Sept. 30, 1970 ........ 223,883.13
The deficiency for the year ending September 30, 1966, resulted from adjustments to income for the year ending September 30, 1969, which led to a...
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