WITHEY, Judge:
Respondent determined a deficiency in petitioner's income tax for 1949 in the amount of $6,609.78.
The issue presented for our decision is the correctness of the respondent's action in determining that petitioner was availed of during 1949 for the purpose of avoiding the imposition of surtax upon its shareholder within the meaning of section 102 of the Internal Revenue Code of 1939.
FINDINGS OF FACT.
Some of the facts...
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