OPINION OF THE COURT

Affiliated Development Corp., a Virgin Islands inhabitant foreign corporation, appeals from a judgment affirming deficiencies in income tax for the years ending November 30,1982 and November 30,1983, a penalty under 26 U.S.C. § 6661 for the year ending November 30, 1983, negligence penalties under 26 U.S.C. § 6653(a) for both years, and late filing penalties under 26 U.S.C. § 6051 for both years. The legal issues presented are discussed in the opin *648 ion filed in Business Ventures International Inc. v. Olive, Nos. 88-3872, 89-3012, 893 F.2d 641, (3d Cir. January 1990). For the reasons set forth therein, the judgment appealed from will be reversed to the extent that it affirmed the assessed deficiencies and penalties for the year ending November 30, 1983, but affirmed to the extent it affirmed assessment of a deficiency in taxes, and penalties, for the year ending November 30, 1982.