MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
By notice of deficiency dated March 11, 2004, respondent determined deficiencies in petitioner's Federal income taxes as follows:
Taxable (Fiscal) Year Ended May 31 Deficiency 1992 $898,237 1993 1,182,805 1994 1,165,619 1995 ...
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