Memorandum Findings of Fact and Opinion
TRAIN, Judge:
In this proceding respondent determined a deficiency in petitioners' income tax for the calendar year 1954 in the amount of $69,116.31. The deficiency results from the addition to income reported of $101,850 said to be the amount of a dividend distribution to petitioners by a family corporation in the guise of a sale of stock to the corporation and the disallowance of a claimed casualty loss deduction...
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