MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies of $7,352,495, $2,802,710, and $1,793,801 in petitioner's Federal income taxes for its years ended September 30, 1995, 1996, and 1997, respectively. Ten separate adjustments were set forth in the statutory notice, and petitioner raised a new issue in its petition. Seven issues were settled by the parties before trial, and one (the research credit issue) has been deferred...
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