Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioner assails respondent's determination of deficiencies in income tax for 1947 of $172.50, and in personal holding company surtax for 1947 and 1948 in the amounts of $4,030.34 and $3,825.11, respectively. All of those amounts are in dispute. An issue as to a small interest income item has apparently been abandoned by petitioner. Petitioner claims an overpayment in income tax for 1947 in the amount...
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