The respondent determined deficiencies in income tax against the petitioner for the years 1956 and 1957 and for the taxable period from January 1, 1958, to June 30, 1958, in the amounts of $59,527.80, $45,110.91, and $3,818.46, respectively. The only issue for decision is whether the petitioner's predecessor, Alles & Fisher, Inc., was subject to the accumulated earnings tax imposed by section 531 of the Code.
FINDINGS OF FACT
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