Memorandum Opinion
VAN FOSSAN, J.:
The respondent determined deficiencies in income tax for the years 1938 and 1939 in the respective amounts of $4,195.28 and $2,674.23, consequent on his holding that the petitioner had permitted its earnings and profits to accumulate beyond the reasonable needs of its business for the purpose of preventing the imposition of surtax on its shareholders.
[The Facts]
Petitioner corporation was formed...
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