OPINION.
MULRONEY, Judge:
Respondent determined a deficiency in the petitioners' income tax for the year 1953 in the amount of $109.38.
The sole question in the case is whether petitioner, a stockholder in a banking corporation, received a taxable dividend by virtue of a transaction wherein the bank transferred stock which it owned in a securities company to trustees for the benefit of all the bank stockholders.
All of the facts have...
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