Memorandum Findings of Fact and Opinion
The Commissioner determined for 1946 a deficiency of $1,029.82 in income tax and a deficiency of $8,844.83 in surtax under section 102. The only issue for decision is whether the taxpayer was availed of for the purpose of preventing the imposition of surtax upon its stockholders through the medium of permitting earnings or profits to accumulate beyond the reasonable needs of the corporation instead of dividing or distributing...
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