Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding involves deficiencies in income tax in the amount of $10,350.66, declared value excess-profits tax of $964.78, and personal holding company surtax of $34,603.05, for the calendar year 1940. The petitioner filed its returns for those taxes for the period involved with the collector of internal revenue for the fifth district of New Jersey. The issues are (1) whether royalties received by...
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