Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency of $28,144.31 in the income tax of the petitioners for 1954. The issues for determination are the correctness of the respondent's action (1) in determining that the proceeds received by the petitioners in 1954 from the sale of shares of stock in one corporation to another corporation, each of which was controlled by petitioners, constituted a dividend taxable...
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