Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent has determined a deficiency in income tax for the year 1940, in the amount of $4,690.86. A small adjustment is not contested. The deficiency results chiefly from the determination by respondent that petitioner was availed of in the taxable year for the purpose of preventing the imposition of the surtax on its sole stockholder, so as to be liable for surtax under section 102(a) of the Internal...
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