Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined a deficiency in petitioners' 1954 income tax in Docket No. 83701 of $15,800.32 and in Docket No. 83702 of $6,311.93. The questions for decision are whether respondent correctly determined that the individual petitioners in Docket No. 83701 received a distribution from a corporation which was taxable as a dividend, and whether respondent
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