Memorandum Findings of Fact and Opinion
Respondent has determined a deficiency in petitioner's income tax for the calendar year 1949 in the amount of $6,157.42. The sole issue is whether a certain payment to petitioner by a corporation constituted the partial repayment of a loan as contended by petitioner, or a taxable dividend, as determined by respondent.
Findings of Fact
Petitioner is an individual residing at 1120 Park Avenue, New York City...
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