Memorandum Opinion
HARRON, Judge:
The Commissioner determined a deficiency in income tax liability for the year 1939 in the amount of $1,748.74. Petitioner filed its income and excess profits tax return for the year 1939 with the collector for the second district of New York.
The record consists of a stipulation of certain facts and the income tax returns of petitioner and of Pacific Metals Corporation, 60 per cent of the stock of which is owned...
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