Memorandum Findings of Fact and Opinion
ATKINS, Judge:
Respondent determined deficiencies in income tax against the petitioners for the taxable years 1963 and 1964 in the amounts of $13,271.93 and $13,185.01, respectively. Certain issues having been conceded by petitioners, the only issue remaining for decision is whether petitioners realized dividend income as the result of redemptions of stock during 1963 and 1964, which stock had been donated by petitioner...
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