OPINION2
CHIECHI, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax:
TYE Deficiency Dec. 31, 1981 .............................. $5,663,086 Dec. 31, 1983 .............................. 11,454,565 Dec. 31, 1984 .............................. 40,433,142 Dec. 31, 1985 ..................
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