OPINION.
BLACK, Judge:
The Commissioner has determined deficiencies against petitioner for the year 1940 of $1,138.23 in income tax and $9,221.34 in personal holding company surtax, plus a 25 per cent penalty amounting to $2,305.34 for failure to file a personal holding company return on Form 1120H. The deficiencies are based upon two adjustments which the Commissioner made on the income tax return filed by petitioner and on the determination by the...
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