ARUNDELL, Judge:
Respondent determined deficiencies in income tax for the calendar years 1951 and 1952 in the amounts of $17,568.54 and $15,131.24, respectively.
The only issue remaining is whether the respondent erred in determining that petitioner was subject to the surtax imposed by section 102 of the Internal Revenue Code of 1939, as amended, for each of the above-mentioned years. Another issue was raised by the pleadings but was abandoned at the...
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