Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in petitioner's income tax for the fiscal year ended October 31, 1959, in the amount of $17,218.85. Of this amount, $100 was the result of a bookkeeping error and has been conceded by petitioner.
The sole issue for decision is whether petitioner is subject to the accumulated earnings tax imposed by section 531 of the Internal Revenue Code of 1954.
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