Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
Fiscal Year Ending Deficiency May 31, 1976 ........... $ 4,349.00 May 31, 1977 ........... 51,046.00
The sole issue for decision is whether income realized by petitioner from sales of certain items of tangible personal property during its fiscal years 1976 and 1977 should...
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