Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $1,275.86 in the petitioner's income tax for the year 1940 and a deficiency of $18,480.79 in its excess-profits tax for the year 1941.
The single issue is whether or not the determination of the petitioner's equity invested capital is based on the original earnings and profits of a transferor corporation acquired by the petitioner in connection with a nontaxable reorganization...
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