Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined deficiencies for the year 1939 as follows: $28,789.51 in income tax; $14,157.04 in declared value excess profits tax; and $28,048.83 in personal holding company surtax. Respondent added to the personal holding company surtax the sum of $7,012.21, 25 percent of the amount of the surtax, because petitioner failed to file a personal holding company return within the time prescribed...
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