The Commissioner has determined a deficiency of $4,355.79 in petitioner's income tax for the year 1938. Only a part of the deficiency is disputed. In his determination of the deficiency the Commissioner disallowed petitioner any dividends paid credit and in that connection stated in his deficiency notice as follows:
On February 12, 1937, Henry J. Coleman, as agent for three individuals, entered into an agreement with Sinclair-Wyoming Oil Company whereunder that corporation...
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