Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency in income tax against petitioners, husband and wife, for 1962 in the amount of $7,896. The only issue remaining is whether the husband ("petitioner") received dividend income by reason of his purchase of 650 shares of stock of Sealtron Corporation on April 2, 1962, at $10 a share from his wholly owned corporation, Sealtron Electronics, Inc. The Commissioner determined...
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