Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent has determined deficiencies in the Federal income tax of petitioner in the amount of $12,763 for the taxable year 1968.
We are asked to decide whether certain payments received by petitioner from a corporation wholly owned by him were loans or dividends.
Findings of Fact
Certain facts were stipulated by the parties and are so found.
Petitioner, Walter H. Johnson...
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