Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner's Federal income tax liabilities for the following taxable years:
Taxable Year Deficiency 1978 ......................... $1,520,238 1979 ......................... 1,713,878 1980 ......................... 1,714,266 1981 ......................... 1,712,071 1982 ...........
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