Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent has determined deficiencies in the income tax of petitioner for the taxable years 1968 and 1969 in the amounts of $6,572.15 and $11,371.63 respectively.
Due to concessions by the parties, the sole question before the Court is whether petitioner is liable for the surtax under section 531
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