Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined deficiencies in petitioner's income tax and personal holding company surtax for the years 1951 and 1952 as follows:
Income Tax Taxable Year Deficiency 1951................. $ 3,814.79 1952................. 1,620.14 Personal Holding Company Surtax 1951................. $71,747.43 1952......
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