PER CURIAM.
The petitioner-taxpayer appeals from a decision of the Tax Court denying a capital gain allowance with respect to certain income. The issues presented on this appeal are, (1) whether the Tax Court correctly held that income received by the taxpayer in exchange for certain stock came within the purview of I.R.C. § 304(a)(1) and was therefore taxable by virtue of §§ 301, 302, and 316 as a dividend,
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