The respondent has determined a deficiency in income tax against the petitioners for the calendar year 1955 in the amount of $43,099.11. The question to be decided is whether the distribution of the stock of the Appleby Building Corporation by the T. Frank Appleby Agency, Inc., to the petitioners in January 1955, was a dividend includible in their gross income or, whether it qualified under section 355 of the Internal Revenue Code of 1954 as a distribution on which no gain...
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