WALLER, Circuit Judge.
Petitioner, a corporation with its principal office in Atlanta, Georgia, is engaged in the sale of refrigerators on installments, with title retained until the installments are paid. The Board of Tax Appeals determined that, under Section 14, Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Acts, page 823, the petitioner (hereinafter frequently referred to as "the company") had an undistributed profits tax liability in the sums of $28,939.60 and $8...
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