Memorandum Opinion
COHEN, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
Tax Year Ended Deficiency March 31, 1981 ...................... $ 19,828 March 31, 1982 ...................... 245,349 March 31, 1983 ...................... 327
After an agreement as to other adjustments, the issue for...
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