Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined a deficiency of $93,965 in petitioner's Federal income tax for 1982. The issue for decision is whether petitioner is liable for the accumulated earnings tax imposed by section 531.
Findings of Fact
Some of the facts have been stipulated and are so found. The stipulation of facts and accompanying exhibits are incorporated herein by...
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