MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
Respondent has determined deficiencies in petitioner's Federal income tax liabilities for the years 1984, 1985, and 1986 in the amounts of $7,152,527, $1,772,936, and $1,668,392, respectively. The parties have reached agreement on certain issues, and the only issue remaining for our consideration is the soundness of certain of petitioner's accounting systems that allow for the accrual of an estimate...
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