Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1954 in the amount of $11,494.60 and additions to the tax under sections 294 (d)(1)(A) and 294(d)(2) of the Internal Revenue Code of 1939 in the respective amounts of $1,119.92 and $726.43.
The issues for decision are:
(1) Whether petitioners during the year 1954 received a dividend from a wholly owned...
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