Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined a deficiency in income tax in the amount of $33,303.28 for the year 1937. In computing the petitioner's surtax on undistributed profits, the respondent did not allow a dividend paid credit or any other credit. The notice of deficiency was mailed October 31, 1939, which, of course, was before the enactment of the Revenue Act of 1942. When this proceeding was first submitted to this...
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