SIBLEY, Circuit Judge.
On April 1, 1940, the petitioner, J. W. Hughes, transferred to his wife 82½ shares of stock in Southeastern Stages, Inc., and in December following a dividend was declared and paid in the company's notes which were themselves paid the following year. This dividend was not included by Hughes in his income tax return for 1940. The Commissioner included it, the only explanation of the adjustment being: "It is held that dividends of $6,250...
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