MEMORANDUM FINDINGS OF FACT AND OPINION
TANNENWALD, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax:
Docket No. Petitioner Year Ended Deficiency 5530-86 Three G Trading Sept. 30, 1980 $1,325,876 Corp., Transferor Sept. 30, 1981 37,588 ...
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