HALPERN, Judge.
By notice of deficiency (the notice), respondent determined a deficiency of $2,015,862 in petitioner's Federal income tax for its taxable year ended May 31, 2004 (taxable year 2004), and an accuracy-related penalty of $403,172.
Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect for taxable year 2004, and all Rule references are to the Tax Court Rules of Practice and Procedure...
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