Memorandum Opinion
STERNHAGEN, Judge:
A deficiency for 1941 of $956.83 in income tax and $1,075.38 in excess profits tax resulted from two adjustments, and the taxpayer assails the holding that it realized income in the amount of the difference between the cost of Union Pacific bonds and their higher fair market value when they were distributed to shareholders as a dividend in kind. All the facts are stipulated.
[The Facts]
The petitioner...
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