The respondent determined deficiencies against petitioner in income taxes for the taxable years ending January 31, 1937 and 1938, in the respective amounts of $85,670.71 and $90,541.54. The principal issue is whether petitioner is entitled to a dividends paid credit under section 27 (f) of the Revenue Act of 1936, by reason of the retirement of preferred stock during the taxable year ending January 31, 1937. There is also raised the subsidiary question whether petitioner...
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