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ANDERSON v. COMMISSIONER

Docket No. 1727-74.

67 T.C. 522 (1976)

RONALD D. ANDERSON AND MARILYN J. ANDERSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 22, 1976.

Attorney(s) appearing for the Case

Robert A. Schnur, for the petitioners.

Joseph R. Peters and John J. Reid, for the respondent.

OPINION

DRENNEN, Judge:

Respondent determined a deficiency in petitioners' income tax for the calendar year 1971 in the amount of $539.83. The ultimate issue for our decision is the extent, if any, to which corporate distributions received by petitioners with respect to their stock in the distributing corporation constituted dividends to them taxable in the year of receipt as ordinary income. This ultimate issue depends upon the extent that such distributions...

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