Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined deficiencies in the income tax of petitioners for 1957 and 1958 in the respective amounts of $2,283.30 and $30,397.45. The issues are whether Bernard Schwartz, who will sometimes be referred to as petitioner, received dividend distributions when his corporation paid premiums on his life insurance policies and his note given in a stock purchase transaction.
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