OPINION.
WITHEY, Judge:
Respondent determined a deficiency in the amount of $1,812.42 in the personal holding company surtax liability of petitioner for 1948.
The sole issue presented by the pleadings is the correctness of the respondent's action in disallowing the inclusion by petitioner in the computation of its dividends paid credit for 1948 of an item representing Federal income tax for 1945, paid in 1946, in the amount of $3,625.47.<...
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