Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined deficiencies of $885,646 and $913,294 in the Federal income tax of petitioner International Minerals and Chemical Corporation and subsidiaries for the fiscal years ended June 30, 1973, and June 30, 1974. After concessions, the sole issue remaining for our decision is whether a sale of certain property by Royster Co. to Wayland Corporation and a contemporaneous lease of that property...
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