Memorandum Findings of Fact and Opinion
SMITH, Judge:
This proceeding is for the redetermination of deficiencies in personal holding company surtax and 25 percent penalties for the calendar years 1937 to 1940 as follows:
Year Deficiency Penalty 1937.................... $ 5,738.76 $1,434.69 1938.................... 6,598.65 1,649.66 1939.................... 6,546.98 1,636.75 1940...
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