Memorandum Findings of Fact and Opinion
In these consolidated cases, respondent determined deficiencies in income taxes as follows:
Docket No. Year Amount 27669 ....... 1946 $138,905.84 32290 ....... 1947 78,418.33
The sole issue is whether during the taxable years petitioner was availed of for the purpose of preventing the imposition of surtax upon its shareholders so as to subject petitioner to...
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