Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined a deficiency in petitioners' income tax for 1959 in the amount of $15,328.73.
The sole issue presented for our decision is the correctness of the respondent's action in determining that the receipt by petitioner Robert H. Herzog of $24,000 from Herzog Supply Co., Inc., in exchange for 240 shares of its preferred stock constitutes the distribution of a dividend to which...
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