The Commissioner determined a deficiency of $52,535.69 in personal holding company surtax for 1942 and a penalty of $13,133.92 for failure to file a personal holding company return.
The issues are (1) whether the petitioner was a personal holding company during 1942, (2) whether the personal holding company surtax is constitutional as applied to the petitioner, and (3) whether the petitioner is liable for the penalty for failure to file a personal holding company...
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