Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
On December 29, 1981, respondent issued a statutory notice of deficiency to petitioner for its fiscal years ended October 31, 1978, and April 19, 1979. Respondent determined deficiencies of $51,624.03 and $278.04 for each year, respectively. After concessions, the issues, remaining for decision are the amount of depreciation petitioner must recapture on the sale of certain assets and the amount petitioner...
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