The respondent determined deficiencies in income tax for the year 1941, as follows: Samuel A. Upham, Docket No. 4022, $84,139.92, and estate of George F. Clark, Docket No. 4129, $32,482.44.
Both petitioners claim refunds. These proceedings have been consolidated. The only issue for determination is whether distributions made by the Brownville Paper Co. in 1941 to petitioners, who are stockholders, were distributions in partial liquidation of the company, or were distributions...
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