Memorandum Opinion
TURNER, Judge:
The respondent has determined deficiencies in personal holding company surtax and penalties against the petitioner as follows:
Docket No. Year Surtax Penalty 109821 1935 $ 341.56 $ 85.39 109822 1938 569.54 142.39 109822 1939 1,657.44 414.36 109822 1940 1,428.23 357.06
The questions presented are (1) whether 80 per cent...
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