Memorandum Findings of Fact and Opinion
The present case involves deficiencies in income and excess-profits taxes of $22,330.13 and $132.17, respectively, for the taxable year ended June 30, 1939. The only question in issue is whether the petitioner corporation was availed of by its stockholders during the year to prevent the imposition of surtaxes on them, by allowing the corporation's gains to accumulate instead of being distributed, and is therefore subject to...
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