Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined deficiencies in personal holding company surtax for the calendar years 1944 and 1945 in the amounts of $2,601.34 and $2,238.15, respectively, and 25 per cent penalties in the amounts of $650.34 and $559.54, respectively, for failure to file personal holding company returns for such years. Petitioner contests the determinations that it had personal holding company income in such...
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