Memorandum Opinion
STERNHAGEN, Judge:
Of a deficiency of $820.97 in 1936 income tax, the taxpayer assails so much as results from the Commissioner's determination that a distribution to the taxpayer by the Weed Iron Company of certificates of the Great Northern Iron Ore Properties was taxable to taxpayer as a dividend. The taxpayer contends that since the value of the certificates when distributed consisted largely of appreciation while owned by the Weed...
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