Memorandum Findings of Fact and Opinion
The respondent has determined a deficiency of $1,963.10 in the income tax liability of the petitioner for the taxable year ended December 31, 1947. The petitioner contests the entire deficiency which is based on the determination that certain corporate distributions to the petitioner in 1947 in cash and property were taxable in full rather than only to the extent that the fair market value of the distributions was covered...
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