DAVIES, District Judge.
The cause was submitted upon the pleadings, evidence, exhibits, and argument of counsel for plaintiff and defendant, and after due consideration thereof the court enters its findings of fact and conclusions of law as follows:
Findings
1. By letter dated October 12, 1940, the Commissioner of Internal Revenue determined a deficiency against plaintiff which included a surtax under Section 102 of the Revenue Act of 1936, 26 U...
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