Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined a deficiency in petitioners' income tax for 1957 in the amount of $11,264.06.
The sole issue presented for our decision is the correctness of the respondent's action in determining that certain cash distributions made by Westley Shipping Company, Inc., to Caribbean Line, S. A., during 1957 resulted in a constructive dividend to petitioner David A. Aylsworth.
Findings...
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