Respondent determined that petitioner was a personal holding company and liable as such for surtax on its income, under section 500 of the Internal Revenue Code, in the amount of $670.68 for the fiscal year ended January 31, 1940, and in the amount of $13,400.53 for the fiscal year ended January 31, 1941. Respondent added 25 percent to the tax for each year for failure to file a personal holding company surtax return under section 291 of the Internal Revenue Code, made applicable...
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