Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency in petitioner's income taxes for the years 1938 and 1939 in the amounts of $16,829.97 and $28,934.66, and excess profits taxes for the same years of $394.89 and $1,689.40, respectively. The sole question presented for our consideration is whether or not the petitioner was liable in either of the taxable years here involved for the tax imposed by section 102 of the Revenue Act of...
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