Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This case involves a deficiency in income tax of $169.74, a deficiency of $9,030.01 in personal holding company surtax, and a 25 per cent penalty in the amount of $2,257.50, all for the fiscal year ended October 31, 1946. Only the $2,257.50 as 25 per cent penalty is placed in issue.
Findings of Fact
Petitioner is a personal holding corporation incorporated with a capital of $3,000 in...
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