Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined that there were deficiencies in income taxes due from the petitioner in the amount of $8,612.23 for the taxable year 1966 and in the amount of $12,701.27 for the taxable year 1967. The sole question involved in the determination of these deficiencies is whether the petitioner is liable for surtax pursuant to section 531,
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