FRANK, Circuit Judge.
The Tax Court found that taxpayer's earnings or profits were permitted to accumulate beyond the reasonable needs of the business. Under the express terms of § 102(c), this finding, if valid, created a presumption that the purpose of the accumulation was to avoid surtax upon the shareholders unless the taxpayer proved the contrary by a clear preponderance of the evidence. The Tax Court found that taxpayer had not done so. Both those findings...
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