Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioner in this proceeding challenges respondent's determination of deficiency in its income and excess-profits tax in the amounts of $10,618.61 and $8,936.40, respectively, for the year 1937. The principal question for determination is whether petitioner is taxable as an association or as a trust. If it is found to be the latter, there is a question of whether petitioner is a distributable or discretionary...
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