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HEATER CORPORATION v. COMMISSIONER

Docket No. 40148.

13 T.C.M. 867 (1954)

T. C. Memo. 1954-151

The Heater Corporation v. Commissioner.

United States Tax Court.

Filed September 15, 1954.

Attorney(s) appearing for the Case

Thomas V. Koykka, Esq., and Fred D. Kidder, Esq., for the petitioner. S. W. Ozark, Esq., for the respondent.

Memorandum Opinion

MURDOCK, Judge:

The Commissioner determined deficiencies in personal holding company surtax and additions under section 291(a), Internal Revenue Code of 1939, as follows:

        Year ended               Deficiency     Addition

  February 28, 1947..........    $91,683.21    $22,920.80
  February 29, 1948..........     38,496.43      9,624.11

The issues for decision are whether amounts received...

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