Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in petitioner's income and excess-profits taxes for the calendar year 1937. That part of the deficiencies is in issue here which arises by reason of respondent's determination that petitioner is liable for the payment of certain surtaxes on undistributed profits. The principal question presented is whether petitioner is entitled to a dividends paid credit during the taxable year.
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