Memorandum Findings of Fact and Opinion
The Commissioner determined income tax deficiencies of $419.88, $354.76, $946.69 and $655.83 for the years 1938, 1939, 1940 and 1941. The questions to be determined are (1) whether certain amounts paid by Gumbiner Amusement Company, a corporation, for and in behalf of petitioner in each of the taxable years are dividends and taxable to him as such, and if so, (2) whether the assessment and collection of deficiencies for 1938...
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