Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes in the amounts of $1,774 and $11,622 for the taxable years ending August 31, 1973, and August 31, 1975, respectively. The issues for decision are: (1) whether petitioner was availed of during the year ending August 31, 1975, for the purpose of avoiding Federal income tax with respect to its shareholders, by permitting its earnings...
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