SULLIVAN, District Judge.
This is an action brought for the refund of income taxes for the calendar year 1936.
The question presented is whether a dividend paid upon corporate stock purchased under an installment payment agreement, providing that pending final payment any dividend paid should be applied as a part of the purchase price, is taxable to the purchaser under Section 22(a) of the Revenue Act of 1936, 26 U.S.C.A. § 22(a), when title to the stock...
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