Memorandum Opinion
DAWSON, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the years 1967 and 1968 in the amounts of $25,262.03 and $24,157.78, respectively.
The primary issue for decision is whether the petitioner, part of whose stock was held in trust, qualified as a small business corporation under section 1371(a), Internal Revenue Code of 1954,
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