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MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:2 Respondent determined deficiencies in, and
additions to, Federal income tax and penalties as follows:
H Group Holding Inc. and Subsidiaries
Taxable year
ending Deficiency
Jan. 31, 1980 $7,681,409
Jan. 31, 1981 5,658,067
Jan. 31, 1982 6,677,731
Jan. 31, 1983 40,311
Jan. 31, 1984 6,768,120
Jan. 31, 1985 799,024
Jan. 31, 1986 19,397,355
Jan. 31, 1987 9,153,141
Jan. 31, 1988 13,176,113
2 These consolidated cases were reassigned to Judge Joel
Gerber by a Feb. 25, 1999, order, following the death of Judge
Theodore Tannenwald, Jr. The parties agreed that the issues
tried to the Court in the trials conducted by Judge Tannenwald
could be reassigned to another Judge without the need for a
retrial or the presentation of additional evidence.
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