MARTIN, Circuit Judge.
The taxpayer, Gilbert E. Nelson, has sought review of the decision of the Tax Court (one judge sitting), holding that payments of $7,960.32, $7,347.90, and $5,308.34, made to his mother in the respective taxable years 1945, 1946, and 1947, by the G. E. Nelson Company, a Michigan corporation of which he was the president and majority stockholder, were taxable to him as dividends constructively received.
We find from the record that the...
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