MADDEN, Judge.
The petitioner Casey in 1953 acquired all the assets of Bankers Development Corporation, and thereby became liable for Bankers' unpaid taxes. The Tax Court held that Bankers had incurred corporate surtax liability for its taxable year ended April 30, 1950, under section 102 of the Internal Revenue Code of 1939 (26 U.S.C. 1952 Ed., § 102). Section 102(a) imposes a tax, in addition to the taxes normally imposed upon corporations, upon the income...
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