Memorandum Opinion
WRIGHT, Judge:
This case is before the Court on petitioners' motion for summary judgment. Respondent determined deficiencies of $2,069 and $4,914,072.50 in petitioners' Federal income tax for taxable years 1985 and 1986, respectively. Petitioners allege in their motion for summary judgment that there is no genuine issue as to any material fact and that a decision should be rendered as a matter of law that petitioners' carryovers of investment...
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