Memorandum Findings of Fact and Opinion
ARNOLD, Judge:
The Commissioner determined income tax deficiencies for 1937 and 1941 in the respective amounts of $90.50 and $945.43. The issues are (1) whether certain dividends paid over in 1937 and 1941 were constructively received during the years in which such dividends were declared and set aside; and (2) whether petitioner is entitled to deduct attorney fees of $500 and administrator fees of $500 in 1941 for...
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