ALDRICH, Circuit Judge.
This is a petition by a corporate taxpayer to review a decision of the Tax Court upholding a tax for the years 1950, 1951, and 1952 under section 102(a) of the Internal Revenue Code of 1939. This section imposes an additional tax upon corporations (other than personal holding companies) "* * * if such corporation * * * is * * * availed of for the purpose of preventing the imposition of the surtax upon its shareholders or the shareholders of...
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