Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in corporate income taxes of petitioner. The Zeropack Company for its fiscal years ended June 30, 1977, and June 30, 1978, in the respective amounts of $286,999.21 and $19,223.04.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision the portion of the $2.8 million paid by petitioner to acquire the...
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