The respondent determined a deficiency in petitioner's income tax for the calendar year 1944 in the amount of $3,552.40. Certain adjustments made by respondent are not contested. The primary question is whether certain securities and cash received by petitioner from the Western Pacific Railroad Co. in a reorganization under section 77 of the Bankruptcy Act constituted a payment of interest and dividends taxable in full, or whether such transaction comes within the provisions...
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