Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax as follows:
Year Ended Deficiency March 31, 1979 ................ $26,713.23 March 31, 1980 ................ 27,078.70 March 31, 1981 ................ 21,345.78
The sole issue for determination is whether petitioner is liable for the accumulated earnings...
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