Respondent determined a deficiency in petitioners' income tax of $22,049.67 for the calendar year 1950. The only question is whether $50,000 received by petitioner Henrietta A. Sorin is taxable as ordinary income as a distribution from a collapsible corporation under section 117 (m), I. R. C. 1939. Other adjustments in the notice of deficiency are not contested.
FINDINGS OF FACT.
Certain facts are stipulated and are hereby found.
Petitioners Arthur...
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