Memorandum Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in the Federal income tax of petitioners for the taxable years ended April 30, 1972, April 27, 1975, and April 25, 1976, in the respective amounts of $163,952, $145,943.50, and $589,392.18. We have this matter before us on the parties' cross-motions for partial summary judgment.
These issues are presented for our decision:
(1) whether section 482, Internal Revenue Code...
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