Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
Respondent determined deficiencies in petitioner's income tax for the calendar years 1947 and 1948 as follows:
Year Deficiency 1947 ....... $44,178.15 1948 ....... 44,037.44
The issues presented for decision are as follows:
Did the Commissioner err in holding:
(1) That the petitioner in 1947 and 1948 was subject to surtax under section 102...
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