MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
This consolidated case was submitted to the Court without trial. See Rule 122(a). Lykes Energy, Inc. (Lykes) and Subsidiaries petitioned the Court to redetermine the following Federal income tax deficiencies:
Taxable Year Deficiency 1988 ............................ $1,075,219 1989 ............................ 1,023,665 1990 .....................
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