Memorandum Findings of Fact and Opinion
The respondent determined deficiencies of $73,718.84 and $130,563.28 in the petitioner's income taxes for the years 1936 and 1937, respectively.
The sole issue is whether or not petitioner is entitled to a credit under the provisions of section 26 (c) (1) of the Revenue Act of 1936 because it was prevented from declaring dividends by the terms of written contract, pursuant to which the petitioner agreed not to "declare...
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