OPINION OF THE COURT
GIBBONS, Chief Judge:
Business Ventures International, Inc. (the taxpayer) appeals from a judgment of the District Court for the Virgin Islands affirming in part deficiency notices issued by the Virgin Islands Bureau of Internal Revenue for the taxpayer's tax years ending November 30, 1982 and November 30, 1983. The Bureau of Internal Revenue cross appeals from the same judgment with respect to certain penalties which it assessed but...
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