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CITIZENS MUTUAL INVESTMENT ASSOCIATION v. COMMISSIONER

Docket No. 108572.

2 T.C.M. 177 (1943)

Citizens Mutual Investment Association v. Commissioner.

United States Tax Court.

Entered May 25, 1943.

Attorney(s) appearing for the Case

Ben F. Johnson, Esq., and J. B. Brennan, Esq., 1516 First Nat'l Bank Bldg., Atlanta, Ga., for the petitioner. J. Y. Porter, Esq., and Chas. P. Bagley, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

This case involves a deficiency in personal holding company surtax for the fiscal year ended March 31, 1938 of $4,546.86 and a 25 percent penalty of $1,136.72. Petitioner's personal holding company return was filed with the collector of internal revenue for the district of Georgia at Atlanta.

The questions involved are the primary ones (1) whether petitioner was a personal holding company within the meaning of section...

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