Memorandum Findings of Fact and Opinion
FISHER, Judge:
Respondent determined deficiencies in petitioner's income tax and additions to tax under section 291(a) of the 1939 Code for the taxable year 1949 in the amounts of $70,634.70 and $17,658.68, respectively.
The issues presented are: (1) whether petitioner received taxable dividend income in the taxable year 1949 upon the withdrawal of the balance in prepaid installment share accounts of William...
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