Memorandum Findings of Fact and Opinion
MELLOTT, Judge:
The Commissioner determined that each petitioner, during the calendar years 1939 and 1940, had permitted its earnings, profits, or surplus to accumulate beyond the reasonable needs of its business and that it had been availed of for the purpose of preventing the imposition of surtax upon its stockholders. He therefore held that each was subject to the surtax prescribed by section 102 of the Internal...
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