Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined a deficiency of $86,549 (including $2,981 in personal holding company tax) in petitioner's (White's Ferry) corporate Federal income tax for White's Ferry's taxable year ending March 31, 1987, and respondent determined that White's Ferry is liable for passive investment income taxes of $32,299 and $19,318, respectively, on net passive investment income for its short taxable year beginning...
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