Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in income and declared value excess profits taxes in the respective amounts of $4,766.48 and $1,428.58 for the calendar year 1942. Petitioner claims an overpayment of income tax.
The only issue is whether petitioner realized any income from the distribution, as a dividend in kind to its stockholders, of notes which had been charged off in previous years, or from subsequent recoveries...
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