The Commissioner has determined a deficiency of $20,875.40 in the petitioner's income tax for 1955. The issues for determination are the correctness of the respondent's action (1) in disallowing a deduction of $18,445 taken as a dividends-received deduction and (2) in disallowing a deduction of $21,700 taken as a dividend paid on a short sale of corporate stock.
FINDINGS OF FACT.
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