MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined deficiencies in, and additions to, Federal income tax and penalties as follows:
H Group Holding Inc. and Subsidiaries
Taxable year ending Deficiency Jan. 31, 1980 ..................... $ 7,681,409 Jan. 31, 1981 ..................... 5,658,067 Jan. 31, 1982 ....................
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