Memorandum Findings of Fact and Opinion
Petitioner contests a deficiency in income taxes for the fiscal year ended September 30, 1947, in the amount of $32,954.17. Petitioner also claims overpayment of its normal tax and surtax for that year in the amount of $2,744.56 as computed in the notice of deficiency.
The sole issue presented is whether petitioner was availed of for the purpose of preventing the imposition of surtax upon its shareholders by permitting...
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