Memorandum Opinion
FAY, Judge:
Respondent determined a deficiency of $76,352 in petitioners' 1976 Federal income tax. After concessions, the issue is whether petitioner Jake E. Roth received a certain payment from a corporation in redemption of his stock or as a dividend distribution.
The facts have been fully stipulated and are so found.
Petitioners, Jake E. Roth and Elizabeth A. Roth, resided in Denver, Colo., when they filed their petition...
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