Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in petitioner's income tax of $2,092.95 and $4,615.38 for the taxable years 1947 and 1948, respectively. The contested issued is whether petitioner is entitled to exclude from gross income its entire net earnings as patronage dividends for each of the taxable years 1947 and 1948.
Findings of Fact
The stipulated facts are...
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