Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes for its taxable years 1975 and 1976:
Taxable year ended Deficiency December 31, 1975 ........... $24,078.31 December 31, 1976 ........... 50,031.90
The deficiency for the taxable year 1975 is not in dispute. After concessions, the deficiency for the taxable year...
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