Respondent determined a deficiency in petitioners' income tax for the year 1951 in the amount of $25,049.82. By an amendment to their petition, petitioners claim an overpayment of income tax for the same year in the amount of "approximately $3,500."
The principal question is whether certain payments made by a corporation to and for a stockholder-employee are taxable as dividends to that employee. Also in issue is whether certain expenditures gave rise to allowable...
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