OPINION
QUEALY, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the calendar years 1970 and 1971 in the amounts of $18,139.05 and $26,476.06, respectively.
The sole question for decision is whether the income resulting from the sale of U. S. Treasury notes distributed to the petitioner as a dividend in kind by Birmingham Trust National Bank (hereinafter sometimes referred to as Birmingham Trust), its subsidiary...
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