Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the taxable years ended March 31, 1980, through March 31, 1986, as follows:
Tax Year Ended Deficiency March 31, 1980 ................... $ 6,054 March 31, 1981 ................... 3,558 March 31, 1982 ................... 321,225 March 31, 1983 ............
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