Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $26,581.02 in petitioner's Federal income tax for the period December 29, 1966 through March 31, 1967. The sole issue for decision is whether the petitioner realized dividend income through the payment of its debt by a corporation of which petitioner was the principal shareholder.
Findings of Fact
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