Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined a deficiency in income tax for the fiscal year ended January 31, 1942 in the amount of $396.88. Petitioner concedes liability for the income tax deficiency.
Respondent determined deficiencies in petitioner's personal holding company surtax liability for the fiscal years ended January 31, 1941 and January 31, 1942 in the respective amounts of $36,267.59 and $50,352.47. Petitioner...
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