Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the calendar years 1968 and 1969 in the amounts of $580.50 and $82,961.33, respectively.
Certain concessions have been made by petitioners, leaving for our decision:
(1) whether petitioners received constructive dividends in 1969 when two corporations in which one of the petitioners owned stock made certain payments...
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