Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding, petitioner challenges respondent's determination of a deficiency in personal holding company surtax in the amount of $49,866.51 for the year 1941.
In his notice of deficiency, respondent also determined deficiencies in income tax in the amount of $318, and in declared value excess-profits tax in the amount of $1,025.81, for 1941, neither of which is controverted by petitioner...
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