Memorandum Findings of Fact and Opinion
HARLAN, Judge:
The Commissioner determined deficiencies of $235.55 and $225 in petitioner's income tax liability for the years 1943 and 1944, respectively. We are presented with two questions:
(1) Whether petitioner realized taxable income from dividends in the amounts of $720, $810, and $900 paid in 1942, 1943, and 1944, respectively, by The Union Bank & Trust Company on 90 shares of its capital stock...
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