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FREDERICK SMITH ENTERPRISE COMPANY v. COMMISSIONER

Docket No. 11158.

6 T.C.M. 594 (1947)

Frederick Smith Enterprise Company v. Commissioner.

United States Tax Court.

Entered June 4, 1947.

Attorney(s) appearing for the Case

Longstreet Heiskell, Esq., 711 First National Bank Bldg., Memphis, Tenn., for the petitioner. Frank M. Thompson, Jr., Esq., and S. Earl Heilman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

By this proceeding petitioner challenges respondent's determination of deficiencies in personal holding company surtax and penalties for failure to file personal holding company tax returns for the years 1937, 1939, and 1940 in the following amounts:

  Year                 Tax Deficiency     Penalty

  1937.................  $19,849.05      $4,962.26
  1939.................   22,695.76...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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