Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1972 and 1973 in the amounts of $13,501.23 and $18,326.25, respectively. Concessions having been made by petitioners, the issues remaining for our decision are: (1) whether petitioner Mandell S. Siff received a constructive dividend in 1972 by virtue of a $30,200 payment made by his wholly-owned corporation to...
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