Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding involves deficiencies in income tax of $20,641.85 for the calendar year 1944 and $431.45 for the calendar year 1945.
The principal issue is whether the respondent erred in taxing certain amounts received by petitioner in 1944 and 1945 from the Park Hosiery Mills, Inc. as the equivalent of distributions of taxable dividends within the purview of section 115 of the Internal Revenue...
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