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AFFILIATED ENTERPRISES, INC. v. COMMISSIONER

Docket No. 106834.

1 T.C.M. 551 (1943)

Affiliated Enterprises, Inc. v. Commissioner.

United States Tax Court.

Entered February 6, 1943.

Attorney(s) appearing for the Case

Albert J. Gould, Esq., 1019 Midland Savings Bldg., Denver, Colo., for the petitioner. J. E. Marshall, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, J.:

Petitioner in this proceeding challenges respondent's determination of a personal holding company surtax deficiency in the amount of $48,132.42 for the year 1937. The single question involved is whether at least 80 percent of petitioner's gross income was personal holding company income.

Findings of Fact

Petitioner was incorporated on November 16, 1933, under the laws of Colorado and its...

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