OPINION
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $23,928.53 in petitioners' Federal income tax for 1970. One issue is left for decision: Whether any part of the proceeds of two life insurance policies, owned by a corporation on the life of decedent J. E. Horne, which were paid to petitioner Amelia S. Horne, the named beneficiary, who owned approximately 41 percent of the stock of the corporation, is taxable as a dividend...
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