Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in the income taxes of petitioners in the amounts of $27,767.07 and $2,938.82 for the years 1969 and 1970, respectively.
The sole issue for consideration is whether distributions of $55,000 in 1969 and $9,400 in 1970 from a corporation, Precision Industries, Inc., to petitioners constitutes dividends to petitioners. Petitioners argue that these distributions...
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