Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding involves a deficiency of $1,754.64 in income tax determined by respondent for the calendar year 1947. The issues are whether petitioner assumed a debt, owed by another person to a corporation of which both were stockholders, as part consideration for the purchase of stock representing the other stockholder's interest in the corporation and, if so, whether petitioner received a dividend...
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