Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for the calendar years 1973 and 1974 in the amounts of $18,355.60 and $1,519.31, respectively, and an addition to tax under section 6651(a)(1), I.R.C. 1954,
The issue for decision is whether petitioner realized a dividend in the amount of $60...
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