Respondent determined deficiencies in petitioner's income tax of $56,832.93 and $58,577.12 for the calendar years 1947 and 1948, respectively. The only issue is whether petitioner is subject to tax under section 102 as having been availed of during the taxable years to prevent the imposition of surtax upon its sole stockholder by permitting earnings and profits to accumulate beyond the reasonable needs of its business instead of being divided or distributed. Petitioner concedes...
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