MAJOR, Circuit Judge.
These petitions are to review decisions of the Tax Court sustaining respondent's determination of a deficiency in the income tax of each of the petitioners for the year 1940. The question involved is identical in each case and they may, therefore, be appropriately disposed of in the same opinion.
On January 26, 1940, the petitioner Edgar M. Soreng received from the Soreng-Manegold Company dividend payments in the sum of $8,804.75, and...
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