Respondent determined a deficiency in petitioners' income tax for the year 1948 in the amount of $3,353.08. The sole issue is whether the proceeds, $13,500, received in a redemption of stock are taxable as a dividend under section 115 (g) of the Internal Revenue Code of 1939 or treated as a distribution in partial liquidation under section 115 (c).
FINDINGS OF FACT.
J. Paul McDaniel (hereinafter referred to as petitioner) and Mary C. McDaniel are husband...
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