Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The respondent determined a deficiency of $13,773.45 in petitioners' income tax for the taxable year 1966.
Petitioners have made concessions and there remains one question for decision: Whether the redemption from petitioner by his wholly-owned corporation of 250 shares of the corporation's preferred stock was essentially equivalent to a dividend.
Findings of Fact
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