OPINION.
ARUNDELL, Judge:
Petitioner challenges a deficiency of $3,644.07 in income tax determined by respondent for the taxable year 1937. The only question for decision is whether petitioner is entitled to a dividend carry-over credit of $16,564.02 on account of dividends paid in 1936 by one of petitioner's predecessor companies in excess of the latter's adjusted net income for that year. The stipulated facts are adopted as our findings.
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