Memorandum Findings of Fact and Opinion
STERRETT, Judge:
In these consolidated cases, respondent determined deficiencies as follows:
Taxable Docket year ended No. Petitioner Dec. 31, Deficiency 5327-72 Calvin Kovens 1968 $2,150,739.13 240-76 Calvin Kovens 1969 1,083,381.18 241-76 Calvin Kovens 1970 227,145.86 and Roz M. ...
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