NIMS, Chief Judge:
Respondent determined a deficiency in Federal corporate income tax of petitioner Rocky Mountain Associates International, Inc., for the taxable year ended December 31, 1980, in the amount of $82,980, and a deficiency in Federal corporate income tax of petitioner Rocky Mountain Associates Export, Inc., for the taxable year ended October 31, 1980, in the amount of $166,059. The issues for determination in this case are: (1) Whether Rocky Mountain...
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