Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding involves deficiencies for calendar years as follows:
1937 ................... $ 492.36 1938 ................... 2,298.92 1939 ................... 1,794.41
The sole issue submitted is whether the petitioner was availed of during the taxable years involved for the purpose of preventing the imposition of surtax upon its shareholders through the medium...
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