Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency of $5,341.50 in the income tax of William H. and Rebecca Cousins for the year 1948. The only issue for decision is whether the amount of $10,000 paid to William by Cousins Laces, Inc., was a dividend or the repayment of a loan.
The Commissioner has determined a deficiency of $9,164.72 in the income tax of Cousins Laces, Inc., for the fiscal year ending October 31, 1948....
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