MAHONEY, Circuit Judge.
This is an appeal from a decision of the Board of Tax Appeals sustaining a determination by the Commissioner of Internal Revenue of deficiencies in the income tax of the Elliott Addressing Machine Company, a Massachusetts corporation, in the amounts of $11,659.48 for 1936 and $5,386.62 for 1937. The petitioner claimed that it was entitled to the undistributed profits surtax credits under Section 26(c) (1) and (2) of the Revenue Act of 1936...
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