Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in excess profits tax for 1943 in the amount of $53,438.30. He also determined overassessments for 1943 of income tax and of declared value excess profits tax in the amounts of $27,277.34, and $271.15, respectively. The sole issue is whether the petitioner is entitled to be classified as a personal service corporation under the provisions of section 725 of the Internal Revenue Code...
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