Memorandum Opinion
TIETJENS, Judge:
The respondent has determined an income tax deficiency of $3,549.58 against the petitioner for the calendar year 1948. The entire amount of the deficiency results from the respondent's determination that dividends in the amount of $17,570 received by the petitioner in June 1948 from the Railway and Utilities Investing Corporation, hereinafter referred to as RUIC, were taxable to the extent of 78.5976 per cent thereof instead...
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