Memorandum Findings of Fact and Opinion
ARNOLD, Judge:
This case involves a deficiency of $3,564.06 in income tax for 1938. The issue is whether dividends received in 1938 on certain stock held by petitioner should be treated as his separate income or as community income of petitioner and his wife. Petitioner alleges that he and his wife were residents of Dallas, Texas, in 1923 or 1924 when an oral agreement was made under which he was to receive stock in...
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