Memorandum Findings of Fact and Opinion
KERN, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1939 in the sum of $1,895.83. That part of the deficiency which is here in issue resulted from his determination that petitioner was not entitled to a dividends-paid credit under section 27 of the Internal Revenue Code for the reason given that there was no deficit in petitioner's accumulated earnings and profits as of...
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