Memorandum Findings of Fact and Opinion
HILL, Judge:
This proceeding involves a deficiency in income tax for the calendar year 1938 in the amount of $3,370.65. Three questions must be decided, namely,
(1) Is a so-called corporate dividend in the sum of $18,750 taxable to petitioner's wife and children, the record owners of the stock, or to petitioner?
(2) Is petitioner to be treated as the...
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