Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in income tax totaling $558.86 for the calendar years 1947 and 1948 and a personal holding company surtax liability of $8,340.10 plus a penalty of $2,085.03 for failure to file a timely return for the year ended December 31, 1948.
The income tax deficiencies are uncontested.
The issues for decision are: (1) Whether petitioner is liable as a personal...
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