PER CURIAM.
Taxpayer appeals from a decision of the Tax Court, T.C.Mem. 1962-300, sustaining the Commissioner's assessment of a penalty tax under section 531 of the Internal Revenue Code of 1954 on accumulated earnings for the year 1956.
Taxpayer replied to the Commissioner's section 534(b) notification with a statement of the grounds on which it relied pursuant to section 534(c). That statement, consisting of various items summarized under five major grounds...
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