OPINION.
MULRONEY, Judge:
The respondent determined a deficiency in income tax for the calendar year 1947 in the amount of $60,902.38. The only issue is whether a distribution of $200,000 in 1947 to the petitioner by a corporation, in which he was the controlling stockholder, was a taxable dividend to the extent of earnings and profits or a repayment of a loan, evidenced by notes, made by the petitioner to the corporation in prior years. All of the...
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