Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined a deficiency in income tax paid by petitioner for its taxable year ended July 31, 1976 in the amount of $10,428. The only issue for our decision is whether or not petitioner was a member of a controlled group of corporations within the meaning of section 1563(a)(2), I.R.C. 1954 during the taxable year in issue.
Findings of Fact
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