Memorandum Opinion
STERNHAGEN, Judge:
This proceeding involving deficiencies of $145.45 and $11,459.46, income tax for 1937 and 1938, respectively, has been settled by agreement as to all issues except the right of petitioner to a dividend paid credit for 1938. That issue, it is agreed, is controlled by the decision of the United States Supreme Court in Helvering v. Sabine Transportation Co., Inc.,
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