Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $34,004.50 for the taxable year ending December 31, 1965.
The issues for decision are: (1) whether payments made by a subchapter S corporation to Bette should be treated as a dividend or as a redemption of the corporation's stock; and (2) whether that portion...
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