LINDLEY, Circuit Judge.
Petitioners, two stockholders of Edwin L. Wiegand Company owning 2% of its preferred or Class A stock and a like 2% of its Class B stock, seek to reverse the decision of the Tax Court approving the respondent's assessment against them of a deficiency tax for the year 1940 of $1305.50, assessed on the ground that a certain stock dividend declared by the corporation and received by petitioners that year constituted taxable income.
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