Opinion
No. 24575.
July 14, 1971.
Petition to Review a Decision of the Tax Court of the United States.
Cyrus A. Johnson (argued), of Diepenbrock, Wulff Plant, Sacramento, Cal., for appellant.
Paul M. Ginsberg (argued), Lee A. Jackson, Harry Baum, Robert I. Waxman, Attys., Johnnie M. Walters, Asst. Atty. Gen., Tax Division, Dept. of Justice, Washington, D.C., K. Martin Worthy, Chief Counsel, Internal Revenue Service, Washington, D.C., for appellee.
The decision of the Tax Court finding deficiencies in appellant's income taxes for 1964 and 1965 as a Subchapter S corporation is affirmed, based on the opinion rendered, and the findings of fact made, by the Tax Court, on March 17, 1969, 51 T.C. 971.