DOBIE, Circuit Judge.
The Commissioner of Internal Revenue (hereinafter called the Commissioner) assessed against Fides, A. G. (hereinafter called petitioner) a surtax for the year 1936 and a delinquency penalty under Sections 351 and 291 of the Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Acts, pages 936, 920. This tax and the penalty were (after redetermination and adjustment) sustained by the Board of Tax Appeals (hereinafter called the Board, and now the Tax Court...
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