Respondent determined a deficiency in income tax against petitioner for the taxable year 1948 in the amount of $14,041.66. The only issue is whether the redemption of 446 shares of petitioner's stock in a closely held corporation, in consideration for the cancellation in substantial part of the indebtedness of petitioner, was essentially equivalent to the distribution of a taxable dividend, under section 115 (g) of the Internal Revenue Code of 1939.
FINDINGS OF FACT...
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