This proceeding involves a deficiency in personal holding company surtax for the year 1948 in the amount of $2,522.74.
The issue presented is the proper computation of the petitioner's subchapter A personal holding company surtax liability, having regard to the provisions of section 117 (c) (1) of the Internal Revenue Code as applied to a personal holding company reporting income from excess net long-term capital gains.
The stipulated facts are found accordingly...
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