Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined deficiencies in petitioner's income tax for 1961 and 1962 in the respective amounts of $2,143.57 and $2,415.32. The only issue is whether petitioner should be denied the surtax exemption provided for in section 11, Internal Revenue Code of 1954 because of the provisions of section 269 or 1551 of the Internal Revenue Code of 1954...
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