MEDICAL-SURGICAL GROUP, INC. v. COMMISSIONER

Docket No. 68790.

33 T.C. 888 (1960)

MEDICAL-SURGICAL GROUP, INC., A CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 16, 1960.


Attorney(s) appearing for the Case

Thomas A. Madden, Esq., Charles F. Osborn, Esq., and Paul A. Wallace, Jr., Esq., for the petitioner.

George E. Constable, Esq., for the respondent.


OPINION.

DRENNEN, Judge:

The taxes in controversy are personal holding company surtaxes. Respondent determined that petitioner was a personal holding company as defined by section 501(a), I.R.C. 1939, in each of the years 1947 through 1953 and determined deficiencies in personal holding company surtaxes as follows:


Calendar year                           Deficiency

1947 -----...

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