The Commissioner determined a deficiency in income tax of Alfred N. Hoffman and Deli Hoffman in the amounts of $9,362.35 for 1959, $11,520,89 for 1960, and $8,675.07 for 1961. The principal issue is whether Reba Martin, Inc., of which Alfred N. Hoffman was allegedly the sole stockholder, was an electing small business corporation under section 1372 of the Internal Revenue Code of 1954 in the years 1959-61, with the consequence that its undistributed taxable income for those...
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