Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined deficiencies in petitioner's income taxes for the indicated years as follows:
Year Deficiency 1956 ......... $35,065.20 1957 ......... 60,538.25 1958 ......... 28,843.11 1959 ......... 22,758.04
The sole issue before us is whether petitioner is subject to the accumulated earnings tax imposed by sections 531 to 537...
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