ATKINS, Judge:
Respondent determined deficiencies in income tax for the taxable years 1960 and 1961 in the respective amounts of $22,913.59 and $31,396.39.
The parties having settled certain issues by stipulation, the issues remaining for decision are whether the election of East Gate Center, Inc., to be treated as a small business corporation under subchapter S of the Internal Revenue Code of 1954 was terminated under section 1372(e)(5) of the Code...
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