OPINION.
DRENNEN, Judge:
The taxes in controversy are personal holding company surtaxes. Respondent determined that petitioner was a personal holding company as defined by section 501(a), I.R.C. 1939, in each of the years 1947 through 1953 and determined deficiencies in personal holding company surtaxes as follows:
Calendar year Deficiency 1947 -----...
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