Memorandum Opinion
LEECH, Judge:
This matter is now before the Court for redetermination of deficiencies in accordance with a Mandate of the Circuit Court of Appeals for the Third Circuit.
Respondent determined deficiencies in personal holding company surtax under section 351 of the Revenue Act of 1934, and included penalties for failure to file returns of such tax, against the petitioner, as follows:
Personal...
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