TURNER, Judge:
The respondent has determined a deficiency in the petitioner's income tax of $961.81 and a deficiency in its personal holding company surtax of $16,783.53 for the year 1937.
The issues presented by the pleadings are (1) whether the respondent erred in not allowing a deduction of $5,940 representing unemployment relief taxes levied by the Territory of Hawaii upon dividends paid...
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