Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined deficiencies in the income tax of petitioner for the taxable years 1968, 1969, and 1970, in the amounts of $59,226.42, $63,140.24, and $51,490.36, respectively.
The sole issue for decision is whether the petitioner is liable for the surtax under section 531
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