FORRESTER, Judge:
Respondent has determined a deficiency of $16,249.17 in petitioner's 1968 fiscal year Federal income taxes. The issue which we must decide is whether petitioner is liable for the 70-percent personal holding company tax imposed by section 541, I.R.C. 1954.
FINDINGS OF FACT
All of the facts have been stipulated and are so found. Those necessary to an understanding of the case are detailed below...
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