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 $45,251.58 for the taxable year 1964 and in the amount of $60,698.72 for the taxable year 1965. The sole question involved in the determination of these deficiencies is whether petitioner is liable for the surtax pursuant to section 531
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