Memorandum Opinion
OPPER, Judge:
This proceeding, involving a deficiency in 1941 income taxes of $219,560.17, presents the familiar issue of whether the declaration of a dividend in kind results in gain taxable to the declaring corporation.
All of the facts have been stipulated and are hereby found accordingly. Petitioner filed its income tax return with the collector at Wilmington, Delaware. On November 19, 1941, petitioner's board of directors...
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