HAYS, Circuit Judge.
Petitioner seeks review of a decision of the Tax Court which upheld the Commissioner's determination that petitioner was liable for personal holding company surtax for the year 1952. We reverse.
We shall first briefly summarize the circumstances which were held to have made petitioner liable to taxation as a personal holding company.
Until July 1952 Frelbro Corporation owned all the stock in Brown-Longyear Motors, Inc. In July...
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