Memorandum Findings of Fact and Opinion
FAY, Judge:
The respondent determined deficiencies in the petitioners' income taxes, as follows:
Year Amount 1952 ............... $8,670.52 1953 ............... 6,025.78 1954 ............... 6,385.38
The only issue for decision is whether payments to petitioner Paul F. Murphy by a corporation pursuant to a promissory note constitute dividends to him.
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