Respondent determined a deficiency in income tax of petitioners for the year 1951 in the amount of $166.24. The sole question presented is whether any part of a property distribution made by a corporation to its stockholders in the year 1951, at the beginning of which year the corporation had no earnings or profits, during which year the corporation suffered an operating loss, and at the end of which year the corporation had no earnings or profits, is taxable in whole or...
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