Memorandum Findings of Fact and Opinion
OPPER, Judge:
In these consolidated proceedings respondent determined deficiencies in petitioner's income tax of $4,695.60 and $5,301.42 for the years ended June 30, 1952 and June 30, 1953, respectively. One of the issues to be decided is whether petitioner is subject to tax under section 102, I. R. C. 1939, as having been availed of during the taxable years to prevent the imposition of the surtax upon its shareholders...
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