This proceeding involves income tax deficiencies for the taxable years ended August 31, 1936, and August 31, 1937, in the amounts of $3,156.80 and $2,693.99, respectively. Three issues are presented, namely: (1) Are distributions received by petitioner in the years 1936 and 1937 from United Appliance Corporation in excess of the latter's earnings subject to tax under section 115 (d) of the Revenue Acts of 1934 and 1936, to the extent they exceed the basis of United's stock...
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