Memorandum Findings of Fact and Opinion
Respondent determined deficiencies against petitioner in income tax for the taxable years 1938 and 1939 in the respective amounts of $20,417.70 and $14,101.73. The deficiencies result principally from respondent's determination that the petitioner "was availed of during the years 1938 and 1939 for the purpose of preventing the imposition of the surtax upon shareholders within the purview of Sections 102 of the Revenue Act...
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