Memorandum Opinion
TYSON, Judge:
The respondent determined deficiencies in income tax of $49,325.18 for 1936 and $12,334.30 for 1937. The sole question presented is whether the petitioner should be allowed dividends paid credits in the taxable years for dividends paid in shares of its common stock. All of the facts have been stipulated and those not set forth herein are included by reference.
[The Facts]
The petitioner is a Delaware...
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