Memorandum Opinion
HARRON, Judge:
The Commissioner determined against petitioner, as a withholding agent, a deficiency in tax of $138,750 for 1940. The question arises under section 144 of the Internal Revenue Code. Petitioner contends that the payments were not subject to withholding. All the facts are stipulated.
[The Facts]
Petitioner, a domestic corporation, had its principal office in New York City. During 1940 petitioner paid...
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