Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in income tax of petitioners for the year 1953 in the amount of $1,995.54. The sole issue for decision is whether the redemption of preferred stock of which petitioner Herbert E. Pliner was the owner of record by the H. E. Pliner Shoe Company was at such time and in such manner as to be essentially equivalent to the distribution of a taxable dividend within the provisions...
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