Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent, in a notice of deficiency dated October 21, 1975, determined deficiencies in income taxes due from petitioner for its taxable years ended September 30, 1966 and 1967 in the amounts of $2,015,299 and $1,130,105, respectively. After various concessions and stipulations the only issue remaining for our decision is the characterization, as currently deductible or capital, of certain payments...
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