Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1966 in the amount of $14,978.98.
The only issue for our decision is whether petitioners received a constructive dividend from a discharge of the obligation of John K. Gordon by a corporation in which he owned 51 percent of the stock when that corporation acquired the 49 percent interest owned by his former wife...
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