FORRESTER, Judge:
Respondent has determined deficiencies in petitioner's Federal income taxes for the fiscal years ended October 31, 1964 and 1965, in the amounts of $20,716.52, and $30,182.19, respectively. Petitioner has conceded one of the issues, consequently the only issue remaining for consideration is whether petitioner's subchapter S status terminated by virtue of its section 1372(e)(5)
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