Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined a deficiency in petitioner's income tax for 1956 in the amount of $25,056.53. The sole issue is whether petitioner was availed of during the year 1956 for the purpose of avoiding the income tax with respect to its shareholders by permitting earnings and profits to accumulate instead of being divided or distributed.
Findings of Fact
Some of the facts were...
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