Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in petitioner's income tax of $5,000 for 1967 and $5,500 for 1968. The sole question is whether petitioner is precluded from claiming a separate corporate surtax exemption under section 269 or section 1551.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
Petitioner is a Florida...
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