Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioner challenges respondent's determination of income tax deficiency in the amounts of $2,260.15 and $3,288.09, respectively, for its fiscal years ending April 30, 1939, and April 30, 1940, and of excess-profits tax deficiency of $1,268.75 for the fiscal year ending April 30, 1939. The single question involved is whether petitioner is taxable as a trust, or as a corporation as the respondent contends...
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