Memorandum Findings of Fact and Opinion
KÖRNER, Judge.
By statutory notice of deficiency dated April 25, 1990, respondent determined deficiencies in petitioner's unrelated business income tax for tax years ended August 31, 1981, 1982, and 1983, in the amounts of $151,344, $288,153, and $376,967, respectively. The issues for decision are: (1) whether respondent erred in determining that a portion of petitioner's circulation income from its periodical...
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