JOHNSEN, Circuit Judge.
The Commissioner determined deficiencies of $35,621.01 and $25,727.93, for the years 1949 and 1950, in petitioner's income taxes. The Tax Court upheld the deficiencies, and the matter is before us on petition for review.
The deficiencies represented surtaxes imposed under the provisions of 26 U.S. C.A.Int.Rev.Code of 1939, § 102(a), that "There shall be levied, collected, and paid for each taxable year * * * upon the net income...
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