Memorandum Opinion
WHITAKER, Judge:
The Commissioner determined Federal income tax deficiencies against petitioner of $784.74, $1,129.48, $2,966.40 and $3,206.20 for the years 1973, 1974, 1975 and 1976, respectively. The only issue for decision is whether petitioner's net income from sponsoring and administering group insurance plans was unrelated business taxable income. All the facts have been stipulated and are found accordingly...
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