MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Wal-Mart Stores, Inc., & Subsidiaries, petitioned the Court to redetermine respondent's determination of deficiencies in their Federal income tax. Respondent determined the following deficiencies:
Taxable Year Ended Deficiency Jan. 31, 1984 (1983 taxable year) ...... $9,937,545 Jan. 31, 1985 (1984 taxable year) ...... 4,084,255 Jan. 31, 1986...
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