Memorandum Findings of Fact and Opinion
BRUCE, Judge:
These consolidated proceedings involve the following deficiencies in income tax for the years 1947 through 1953:
Surtax under Sec. 102 Year Income Tax I. R. C. 1939 1947........ ......... $ 84,892.52 1948........ ......... 201,538.89 1949........ ......... 74,271.79 ...
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