Petitioner asks for the redetermination of deficiencies in personal holding company surtax for the years 1938, 1939, and 1940 in the amounts of $2,293.20, $2,645.46, and $7,912.06, respectively, together with delinquency penalties for the same years of $573.30, $661.37, and $1,978.02, respectively. The questions in issue are (1) whether the petitioner was a personal holding company for the years 1938, 1939, and 1940, and, (2) if so, whether the petitioner is liable for delinquency...
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