Memorandum Findings of Fact and Opinion
LEECH, Judge:
These consolidated proceedings involve income tax deficiencies in the sum of $169,006.14 for the calendar year 1936 and $603,918.22 for the year 1937.
The sole issue is whether the petitioner is entitled to a credit for the taxable years 1936 and 1937 in computing the surtax on its undistributed profits under section 26 (c) (1) of the Revenue Act of 1936.
The cases were submitted on a...
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