Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent has determined a deficiency of $7,928.34 in petitioner's income tax for the year 1941 which petitioner challenges by this proceeding.
The only issue contested by petitioner is respondent's determination that it was liable to section 102 surtax by reason of failure to distribute earnings with the purpose of avoiding surtax on its stockholders.
Findings of Fact
Petitioner...
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