Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined the following deficiencies against the petitioner:
Year Deficiency 1962 ................... $10,682.18 1963 ................... 5,759.69
Mutual concessions having been made, it remains to be determined whether First Finance Company, a corporation of which petitioner was a shareholder, was entitled to elect to be taxed under...
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