Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $1,284.91 and $139,918.95 in petitioner's Federal income taxes for the fiscal years ended October 31, 1975, and October 31, 1976, respectively. The issues are whether certain other corporations were affiliated with petitioner so that they were eligible to participate in a consolidated return; whether petitioner is entitled to deduct certain claimed geological expenses...
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