The Commissioner originally determined a deficiency in petitioner's income tax for the taxable year 1956 in the amount of $745,302.63 on the theory that petitioner was subject to the personal holding company tax. The Commissioner withdrew this issue at the trial and, by amendment to his answer, determined a deficiency in the amount of $286,281.17 on the theory that petitioner was subject to the accumulated earnings tax in 1956. The correctness of the latter determination...
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