Memorandum Findings of Fact and Opinion
SCOTT, Judge:
The respondent determined a deficiency in income tax against the petitioners for 1954 in the amount of $5,327.48.
The issues for decision are whether petitioner, Max Bernstein, received from his solely owned corporation a dividend either formally declared or constructive and, if so, whether he is entitled to a deduction under section 165 of the Internal Revenue Code of 1954, of $16,911.47 for...
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