HAYNSWORTH, Circuit Judge.
Whether the taxpayers received a constructive dividend is the principal question. The Tax Court resolved it against the taxpayers upon a determination that the taxpayers had failed to prove that they had not received such a dividend. We think the case must be reversed upon the ground that the Commissioner has failed to prove that they did.
I.
The taxpayer, Joe W. Stout, was the owner of 63 shares of the common stock of...
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