The respondent determined a deficiency in income and victory taxes in the amount of $126,223.63 for the calendar year 1943. The only issue now in dispute is whether $200,669.34 received by petitioner for 3,202 shares of stock of Air Cruisers, Inc., is taxable as a dividend under section 115 (g) of the Internal Revenue Code.
FINDINGS OF FACT.
A stipulation of facts filed by the parties is adopted as part of our findings.
Petitioner, an individual...
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