Memorandum Opinion
TURNER, J.:
The Commissioner has determined income tax deficiencies against petitioner for the calendar years 1936 and 1937 in the amounts of $17,119.14 and $15,148.76, respectively.
The only issue presented is whether for the purpose of the surtax on undistributed net income the petitioner is entitled to certain credits because of a contract restricting the payment of dividends. All of the facts herein were stipulated by the parties...
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