Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for 1966 and 1967 in the respective amounts of $10,030.63 and $9,363.28. The only issue for decision is whether the petitioner is liable for the accumulated earnings tax for those years.
Findings of Fact
Some of the facts have been stipulated. The stipulation of facts and attached exhibits
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