MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge:
Respondent determined a deficiency of $15,819,650 in petitioner's 1999 Federal income tax. The issue for decision is the value of petitioner's primary asset, the right to divert 168,000 acre feet of water from the Colorado River, upon petitioner's election to be treated as an S corporation effective January 1, 1997.
Our decision relies on the record, which is sufficient in this case to make a...
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