OPINION.
MULRONEY, Judge:
Respondent determined a deficiency in personal holding company surtax for the taxable year 1949 against the petitioner in the amount of $43,172.81. All of the facts are stipulated. The only issue is whether petitioner, in the computation of its personal holding company tax liability for the year 1949, is entitled to a deduction under section 505 (a) of the Internal Revenue Code of 1939 of $49,823.24, paid in that year, which...
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