Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in income tax against petitioner for the calendar year 1938 in the amount of $60,119.59. Petitioner claims an overpayment of income tax for the year of $67,116.44. The only issue for our decision is whether a distribution in partial liquidation on October 2, 1937, by The Miramar Corporation so exhausted its earnings and profits that distributions to petitioner in 1938 were made out of paid...
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