Simpson, Judge: The respondent determined deficiencies in the petitioner’s Federal income tax of $14,606.34 for 1965 and $14,985.76 for 1966. He has also determined 'additions to the tax under section 6651 (a), I.R.C. 1954, 1 of $2,190.95 for 1965 and $749.29 for 1966. Two issues remain for our decision: (1) Whether a corporation, whose status as a small busines…
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