Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a separate $6,500 deficiency in petitioner's 1971 and 1972 Federal income taxes. The sole issue is whether petitioner has established by "the clear preponderance of the evidence that the securing of" an additional surtax exemption "was not a major purpose of" the transfer of property to it at its incorporation within the meaning of section 1551(a).
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