SAVAGE, Chief Judge.
The question presented in this case is whether the additional tax provided by Section 102 of the Internal Revenue Code, 26 U.S.C.A. § 102 should be paid by the World Publishing Company upon the theory that the corporation was availed of in 1944 for the purpose of preventing the imposition of a surtax upon its sole shareholder (except for qualifying shares) through the medium of permitting profits to accumulate instead of being distributed...
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