Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
The Commissioner determined in petitioner's surtax of $21,731.37 for the fiscal year ended July 31, 1940, under section 102, Internal Revenue Code. Petitioner assails the determination that it accumulated earnings and profits beyond the reasonable needs of its business to prevent the imposition of surtax upon its shareholder within the meaning of section 102. A second assignment of error involving an...
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