SETH, Circuit Judge.
The Commissioner filed notices of deficiency against the taxpayer and others in connection with their income tax returns for 1959 and 1960. He determined that redemptions of preferred shares of stock in a closely held corporation from the taxpayer and others were essentially equivalent to the distribution of taxable dividends under § 302(b) (1) of the 1954 Internal Revenue Code.
The Tax Court considered the two redemptions and held...
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