This proceeding was brought for a redetermination of a deficiency of $9,912.96 in personal holding company surtax for 1941, and a penalty of $2,478.24.
The litigated issues are whether petitioner is exempt from the status of "personal holding company" by reason of qualifying as a "bank" as that term is defined in Internal Revenue Code, section 104; whether a sale in 1941, of Miami 2 per cent certificates resulted in income received from the sale of a stock or security...
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