In these consolidated cases respondent determined deficiencies of $329,992.55 and $10,672.98 in petitioners' Federal income tax for the years 1971 and 1972, respectively. The issues for our decision are:
(1) Whether petitioner Arthur C. Smith, Jr., received constructive dividends as a result of corporate redemptions of stock for which he had an unconditional obligation to purchase from his father...
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