MULRONEY, Judge:
The respondent determined a deficiency in the income tax of petitioners for 1953 in the amount of $211,851.
The sole issue in the case is whether Perry E. Bondy received a dividend in the amount of $268,538.67 upon the distribution of 100 shares of stock in P. E. B. Inc. during the taxable year 1953.
FINDINGS OF FACT.
Some of the facts were stipulated and they are found accordingly.
Petitioners Perry E. Bondy...
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