Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency of $2,571.78 in the petitioners' income tax for the year 1949. The only issue presented is the correctness of the respondent's action in determining that a corporate payment of $7,402.80 received by the petitioners was taxable as a dividend under section 115(g) of the Internal Revenue Code. The respondent made one other adjustment which has been conceded by...
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