MEMORANDUM FINDINGS OF FACT AND OPINION
SCOTT, Judge:
Respondent determined deficiencies in the consolidated income tax of Guy Schoenecker, Inc., and its two subsidiaries for the years and in the amounts as follows:
Fiscal year ended Deficiency June 30, 1988 ........................ $ 254,535 June 30, 1989 ........................ 587,024 June...
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