The Commissioner determined deficiencies for 1946 in section 102 surtax of $4,577.60 in the case of Latchis Theatres of Keene, Inc., and $2,118.64 in the case of Latchis Theatres of Claremont, Inc. The question for decision is whether the earnings or profits of each of these petitioners were permitted to accumulate in 1946 beyond the reasonable needs of the business so that as a result the corporation was availed of for the purpose of preventing the imposition of the surtax...
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