MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies of $94,876, $75,398, and $62,569 in petitioner's Federal income tax for 1995, 1996, and 1997, respectively. The sole issue for decision is whether, for each of the years in issue, petitioner was a corporation described in section 532, i.e., a corporation availed of for the purpose of avoiding income tax with respect to its shareholders, by permitting its earnings and...
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