Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined a deficiency in income tax in the amount of $44,819.53 for the calendar year 1962. The only issue presented is whether the payment of $59,760 to petitioner W. P. Bunton, Sr., by the Bunton Seed Company reimbursing him for the amount he had previously paid to two minority stockholders for all of their stock in the corporation constitutes a dividend. Another issue raised in the petition...
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