OPINION
SCOTT, Judge:
Respondent determined deficiencies in petitioner's Federal corporate income tax for its fiscal years ending September 30, 1969, 1970, and 1971 in the amounts of $70,057.43, $53,814.85, and $20,644.72, respectively.
The issues for our decision are (1) whether petitioner's election in 1958 to be taxed as a small business corporation under section 1372, I.R.C. 1954,
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