OPINION.
RICE, Judge:
This proceeding involves a deficiency in income tax for the year 1949 in the amount of $4,820.81.
The only issue is whether the redemption of preferred stock which decedent owned was "at such time and in such manner" as to make it "essentially equivalent to the distribution of a taxable dividend" within the meaning of section 115 (g) of the 1939 Code. All other issues raised in the petition were conceded.
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