Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent has determined deficiencies in petitioner's income tax liability for the fiscal years November 30, 1954, and November 30, 1955, in the amounts of $25,608.51 and $24,455.96, respectively.
The issue for decision is whether petitioner qualified as a Western Hemisphere trade corporation under section 109 of the Internal Revenue Code of 1939 for the taxable year ended November 30, 1954,...
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