Memorandum Opinion
RAUM, Judge:
The Commissioner determined income tax deficiencies of $5,866.76 and $6,750.40 for the taxable years ended September 30, 1975, and September 30, 1976, respectively, for Whitaker Construction Co. (petitioner). The only issue for decision is whether petitioner was a component member of a brother-sister controlled group of corporations and thus required to share a single surtax exemption with its sister corporation. All of the...
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