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HAYS v. COMMISSIONER

Docket No. 2219-69 SC.

30 T.C.M. 378 (1971)

T.C. Memo. 1971-95

William O. Hays and Margery J. Hays v. Commissioner.

United States Tax Court.

Filed May 3, 1971.

Attorney(s) appearing for the Case

Claude L. Eichel, City Nat'l Bank Bldg., Miami, Fla., for the petitioners. W. Reeder Glass, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

Respondent determined a deficiency of $750 in petitioners' income tax for the taxable year 1966. The sole question before us is whether the redemption of certain preferred stock owned by petitioner William O. Hays was essentially equivalent to a dividend under sections 302 and 316.1

Findings of Fact

Some of the facts were stipulated. The stipulation and...

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