Respondent determined a deficiency of $18,886.95 in petitioner's income tax liability for 1946. The sole issue presented is whether a dividend declared and made payable in 1946 but received through the mails in 1947 was "constructively received" by petitioner in 1946 so as to be includible in his gross income for the earlier year.
Some of the facts have been stipulated.
FINDINGS OF FACT.
The stipulated facts are hereby found.
Petitioner is...
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