Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in income tax and section 102 surtax totaling $272,691.83 for 1947 and $72,449.25 for 1948. Issues bearing on the income tax deficiencies have been settled and can be reflected in a Rule 50 computation. The only question for decision is whether the earnings or profits of the petitioner were permitted to accumulate in the taxable years beyond the reasonable needs...
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