Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency of $23,811.46 in petitioners' 1966 Federal income taxes. After petitioners' concessions, the sole issue is whether payments made by two corporations partially discharging Federal income tax liabilities of Morna R. Schwartz for prior years are taxable to her as constructive dividends.
Findings of Fact
Some of the facts were stipulated and are found accordingly...
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