OPINION.
BLACK, Judge:
The Commissioner has determined a deficiency in petitioner's income tax for the year 1937 of $441.15. The deficiency is due to the addition of $7,316 dividends to the income reported on petitioner's income tax return. This adjustment is explained in the deficiency notice as follows:
(a) It is held that the sum of $7,316.00 representing dividends derived on the shares of Pioneer Building and Loan Company constituted income...
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