Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency of $4,869.00 in the petitioner's income tax for the calendar year 1939 and a deficiency of $10,733.00 in its personal holding company surtax for the same year. The facts were supplied solely by a stipulation of the parties and are hereby found as stipulated.
The Commissioner, in determining these deficiencies, has included in the petitioner's income for 1939 the amount of...
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