Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency in the petitioner's income tax for the calendar year 1940 in the amount of $14,827.26. The deficiency resulted from the Commissioner's determination that dividends in the amount of $27,500 were income in 1940 rather than in 1939. The propriety of the inclusion of the dividends in 1940 income is the only issue. The facts have been stipulated.
[The Facts]
The...
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