MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined deficiencies in petitioner's consolidated Federal income taxes in the respective amounts of $28,415, $22,495, $465,115, $24,108, and $45,837 allegedly for petitioner's 1990, 1991, 1992, 1993, and 1994 taxable years.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court...
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