Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency in petitioner's Federal corporate income tax in the amount of $328,549 for its fiscal year ended June 30, 1981.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in question, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After a concession,
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