Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income taxes for the taxable years 1966 and 1967 in the amounts of $132,548.63 and $147,492.61, respectively. Some of the issues raised by the pleadings have been disposed of by agreement of the parties. The only issue remaining for decision is whether, for each of the years in issue, petitioner was formed or availed of for the purpose of avoiding income...
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