Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in income tax for the year 1946 in the amount of $2,948.12. The sole issue is whether petitioner was availed of during the taxable year for the purpose of preventing the imposition of surtax upon its stockholders so as to subject petitioner to the surtax provided for by section 102 of the Internal Revenue Code.
Findings of Fact
Petitioner, an Arkansas corporation with its...
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