Memorandum Findings of Fact and Opinion
HILL, Judge:
This proceeding involves income tax deficiencies determined against petitioner for its taxable years ended March 31, 1939 and March 31, 1940, in the respective amounts of $3,683.65 and $8,918.98. The single question is whether petitioner, a corporation, was availed of during the years in question for the purpose of preventing the imposition of the surtax upon its sole shareholder through the medium of...
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