OPINION.
ARUNDELL, Judge.
Proposed deficiencies in income (withholding) tax amounting to $2,630, $76,677.22, and $51,263.58 for the years 1936, 1937, and 1938, respectively, are the subject of the present controversy. The issues are whether amounts paid in redemption of preferred stock were essentially equivalent to the distribution of taxable dividends; and, if so, whether they should be treated as such in the hands of nonresident alien stockholders...
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