Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a $168,105.62 deficiency in petitioner's 1984 Federal income tax. After a concession by respondent, the sole issue for decision is whether petitioner was a personal holding company liable for the section 541 personal holding company tax. All section references are to the Internal Revenue Code for the year in issue, and all Rule references are to the Tax Court Rules of Practice and...
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