The Commissioner determined a deficiency in petitioner's income tax for the calendar year 1941 in the amount of $249,961.29 and a penalty in the amount of $12,498.06.
The principal question at issue is whether the Pullman Co. canceled or redeemed 50,000 shares of its stock owned by petitioner in such a manner as to make the distribution of $5,042,500 essentially equivalent to a taxable dividend.
The penalty was asserted by reason of respondent's contention...
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