The Commissioner determined a deficiency of $57,759.75 in income tax of the petitioners for 1955 and one of $174.59 for 1956. The only issue for decision is whether the Commissioner erred in holding that Walter, as a stockholder of Trinidad National Bank, constructively realized dividend income of $100,000 in 1955 resulting from his acquisition of the bank building, worth $133,000, by paying $33,000 to the bank.
FINDINGS OF FACT.
The petitioners, husband...
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