The commissioner determined a deficiency of $3,991.37 in the petitioner's personal holding company surtax for 1938 and imposed a 25 percent penalty thereon amounting to $997.84. He determined no deficiency in income tax for 1938.
The principal issue presented is whether the petitioner realized a capital gain upon the receipt by it in 1938 of a liquidating dividend. A second issue is whether the respondent properly imposed a 25 percent penalty based on the petitioner...
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