Memorandum Findings of Fact and Opinion
OPPER, Judge:
A deficiency in 1958 income tax of $4,048.88 is contested. The issue is whether the payment of $10,500 to petitioner Amleto U. Salvadore by Salvadore Tool & Findings, Inc., in 1958 constitutes a dividend or the repayment of a loan.
Findings of Fact
The stipulated facts are hereby found accordingly.
Petitioners Amleto U. Salvadore (hereinafter referred to as petitioner) and...
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