ATKINS, Judge:
The respondent determined deficiencies in income tax in the amounts of $10,734.55, $12,132.17, and $6,172.21 for the fiscal years ended June 30, 1961, 1962, and 1963, respectively.
The only issue for our decision is whether petitioner was availed of for the purpose of avoiding the income tax on its shareholder by permitting its earnings and profits to accumulate instead of being divided or distributed, with the result that the petitioner...
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