Memorandum Findings of Fact and Opinion.
OPPER, Judge:
Respondent determined deficiencies against petitioner, Hatfried, Inc., for its taxable year ended October 31, 1941, as follows:
Income Tax ................................................................. $ 2,455.98 Personal Holding Company Surtax ............................................ 24,854.51 25 percent Delinquency Penalty on Personal Holding Company Surtax ...........
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