OPINION
HAMBLEN, Judge:
Respondent determined the following deficiencies in petitioners' income taxes for 1979, 1980, 1981, and 1982 (hereinafter sometimes referred to collectively as the years in suit):
Year Amount of deficiency 1979 ............................. $13,674,981 1980 ............................. 28,541,936 1981 ............................. 27,099,275...
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