GOFFE, Judge:
The Commissioner determined deficiencies in petitioner's Federal income tax for the taxable year 1974 in the amount of $80,813,428 and for the taxable year 1975 in the amount of $166,316,320. Petitioner and respondent, with the approval of the Court, agreed that only certain issues set forth in the statutory notice of deficiency, petition, and amended petition would be litigated at a special trial session commencing on July 30, 1984, at Dallas...
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