STRUM, Circuit Judge.
This is a petition to review a decision of the tax court entered January 26, 1951, sustaining the Commissioner of Internal Revenue in determining an aggregate deficiency of $21,306.25 in petitioner's personal holding company surtaxes for 1944, 1945, and 1946; imposing delinquency penalties aggregating $5,326.46 for failure to file returns for those years; and disallowing a deduction for interest in the sum of $4,753.11, claimed by petitioner...
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