Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in personal holding company surtax against the petitioner for the calendar years 1939 and 1940 in the respective sums of $2,183.22 and $1,165.79.
The sole issue is whether the respondent erred in disallowing deductions for expenses and depreciation in respect of certain real estate owned by the petitioner during the taxable years in question.
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