Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent determined deficiencies in income tax in the respective amounts of $857,007.83, $101,529.10, and $2,407,754.29 for fiscal years ending March 31 in 1958, 1959, and 1960, respectively. The sole issue remaining for decision is whether the petitioner is liable for the accumulated earnings tax for the years in issue imposed by sections 531 and 532 of the Internal Revenue Code of 1954. Concessions...
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