Memorandum Findings of Fact and Opinion
NIMS, Judge:
The Commissioner determined a deficiency in the petitioners' Federal income taxes for the taxable year 1976 in the amount of $5,619.52. The sole issue for decision is whether a corporate distribution made to shareholders two and one-half months after the close of the final year of a Subchapter S election constitutes a tax free distribution of previously taxed, undistributed income or a distribution out...
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