Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income tax for the calendar year 1962 in the amount of $133,089.17. The principal issue is whether petitioner constructively received and was properly taxable on $141,000 in cash dividends paid by a corporation in which he had been the sole stockholder where, immediately after the greater portion of the dividends had been declared but before anything had been paid, petitioner...
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