MEMORANDUM OPINION
PARR, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for taxable years 1983, 1984, 1985, and 1986 in the amounts of $3,124, $258,369, $11,537, and $653,673, respectively.
All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. References to petitioner are...
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