The Commissioner determined a deficiency of $19,566.65 in the income tax of the petitioner for its fiscal year ended March 31, 1949. The only issue for decision is whether the Commissioner erred in determining that the petitioner is subject to the surtax imposed by section 102 (a) of the Internal Revenue Code.
FINDINGS OF FACT.
The petitioner was incorporated under the laws of New York on or about March 31, 1948. Its corporate return for the taxable year...
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