NORDBYE, District Judge.
The Louise G. Piper Company was a personal holding company and was dissolved in December, 1935. The Revenue Act of 1934, Section 351, 48 Stat. 751, 26 U.S.C.A. Int.Rev.Acts, page 757, imposes a surtax of thirty per cent (30%) on the "undistributed adjusted net income" of personal holding companies. "Undistributed adjusted net income" equals the adjusted net income less certain deductions, including "dividends paid" during the tax year for...
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