SOPER, Circuit Judge.
This is an appeal from a decision of the Tax Court which upheld an income tax deficiency and penalty in the aggregate sum of $3,111.08 assessed by the Commissioner of Internal Revenue for the year 1941. The principal issue is whether the Tax Court erred in holding that a dividend on stock originally issued to the taxpayer but later transferred by him to his son was taxable to the taxpayer. There is also involved the question whether the Commissioner...
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