The respondent determined deficiencies in income tax for the year 1940 in the sum of $4,307.61 against M. W. Ellis and $4,478.39 against Mina W. Ellis. An issue involving the deduction of $1,817.24 by petitioner M. W. Ellis for ordinary and necessary business expense has been stipulated by the parties and will be settled under Rule 50.
The sole issue now in controversy is whether a corporate distribution received by each of the petitioners in 1940 constituted the...
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