Memorandum Findings of Fact and Opinion
Petitioner contests the correctness of respondent's determination of income tax deficiencies for the calendar years 1937 through 1940 in the respective amounts of $30,471.38, $41,512.33, $69,460.49 and $60,370.76, and of an excess profits tax deficiency in the sum of $5,805.06 for the year 1937. The principal ground of complaint is the Commissioner's holding that petitioner is subject to the surtax imposed by section 102 of...
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