OPINION.
TIETJENS, Judge.
On August 27, 1962, petitioner filed a motion for "Determination of Issues Under Section 534, Internal Revenue Code of 1954." The gist of the motion is a request that the Court determine whether the statement of the grounds on which petitioner relies to establish that none of its earnings and profits were permitted to accumulate beyond the reasonable needs of its business (including the reasonably anticipated needs) is sufficient...
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