MEMORANDUM OPINION
LARO, Judge:
Respondent determined deficiencies of $23,847,089 and $221,968,862 in petitioner's 1979 and 1980 Federal income taxes, respectively. Respondent reflected this determination in a notice of deficiency issued to petitioner on April 2, 1992. Petitioner petitioned the Court on June 30, 1992, to redetermine respondent's determination.
The parties submitted the case to the Court without trial.
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