FISHER, Judge:
This proceeding involves deficiencies in personal holding company surtax and addition to tax under section 291(a) of the Code of 1939 determined by respondent for the taxable years 1951 and 1952 as follows:
Year Personal holding company surtax Sec. 291(a) 1951 -------------------------------- $8,759.95 $2,189.99 1952 -----------------...
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