BRUCE, Judge:
Respondent determined deficiencies in petitioner's income tax as follows:
Year Deficiency 1952 -------------------------------------- $5,168.52 1953 -------------------------------------- 3,724.67
The sole issue is whether dividends in the amount of $29,695.95 declared by petitioner on its earnings for the 6-months' period ended December 31, 1951, were allowable...
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