Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
In two notices of deficiency both dated October 19, 1983, respondent determined deficiencies in the Federal income taxes of Coulter Electronics, Inc., and Subsidiaries as follows:
Year Ended Deficiency 3/31/72 .................... $ 506,299 3/31/73 .................... 2,284,848 3/31/74 .................... 979,371 3/31/75 ..........
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