STEPHENS, Circuit Judge.
This is a petition to review a decision of the Board of Tax Appeals, entered February 18, 1939, approving the determination of the respondent Commissioner of Internal Revenue of a $2,241.44 deficiency in petitioner's income tax for the year 1928 and a penalty of $560.36 for failure to file an income tax return for the same year.
On July 2, 1928, the taxpayer was the owner of 85 shares of the capital stock of Peckham-Case Company, a...
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