Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $36,329,771 and $13,850,028 in petitioner's Federal income tax for 1980 and 1981, respectively. The issue discussed in this opinion, which was separately tried and briefed, relates to petitioner's method of accounting for rotable parts as fixed assets subject to depreciation. We must determine: (1) Whether respondent abused her discretion in determining that petitioner...
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