Memorandum Findings of Fact and Opinion
This case involves a deficiency in income tax for the taxable year 1946 in the amount of $2,178.12. The issue is whether petitioner constructively received a taxable dividend by virtue of the payment of $3,750 to her daughter by a corporation in which the petitioner was the principal stockholder.
Findings of Fact
Petitioner, a resident of Little Rock, Arkansas, filed her income tax return for the taxable...
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