MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
Docket No. 4425-00 Year Deficiency 1993 ..................... $4,046,998 1994 ..................... 2,093,171 1995 ..................... 822,274 1996 ..................... 719,096 Docket No. 8875-00 Year ...
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