MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
The parties submitted this case to the Court without trial. Rule 122(a). Extrusions Division, Inc., petitioned the Court to redetermine respondent's determination of Federal income tax deficiencies for its taxable years ended March 31, 1987 (1986 taxable year), and March 31, 1991 (1990 taxable year). Respondent determined deficiencies of $36,538
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