Respondent determined a deficiency of $534.42 in income tax for the calendar year 1944, together with an addition of the 25 per cent penalty under section 291, in the amount of $862.47, for failure to file a return; respondent also determined a deficiency of $8,043.13 in personal holding company surtax for the calendar year, together with an addition of the 25 per cent penalty under section 291 in the amount of $2,010.78. The issues presented are (1) whether petitioner was...
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