OPINION.
RAUM, Judge:
The respondent determined a deficiency in the amount of $16,801.68 in the income tax of the petitioner for the calendar year 1947. The only issue presented is whether certain stock dividends received by the petitioner in 1947 constitute income under section 115 (f) (1) of the Internal Revenue Code and are thus includible in his gross income.
The facts have been stipulated and are so found. The petitioner, a resident of...
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