Memorandum Opinion
PARR, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the fiscal year ended September 1, 1974, in the amount of $67,552.00 and for the fiscal year ended August 31, 1975 in the amount of $88,241.00. The issue for decision is whether petitioner is precluded by section 1504(b)(4)
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