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ALEX BROWN, INC. v. COMMISSIONER

Docket No. 1162-72.

60 T.C. 364 (1973)

ALEX BROWN, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 11, 1973.

Attorney(s) appearing for the Case

Bennet Kleinman, for the petitioner.

Buckley D. Sowards, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency of $74,552 against petitioner, representing accumulated-earnings tax for the fiscal year ended May 31, 1969. The sole question before us is whether petitioner was availed of for the purpose of avoiding Federal income taxes with respect to its shareholders within the meaning of sections 531 through 537.1

FINDINGS OF FACT

Some of the facts have been stipulated...

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