MULRONEY, Judge:
Respondent determined a deficiency in petitioners' income tax for 1961 in the amount of $19,315.21. The issue is whether a corporate distribution of its debentures in the amount of $40,000 to Joe L. Smith, Jr., in 1961 in exchange for 800 shares of the corporation's common stock constituted a redemption equivalent to a dividend within the meaning of section 302 of the 1954 Internal Revenue Code.
FINDINGS...
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