- 20 - indebtedness were not exempted from tax by section 1041, but were dividends under sections 301, 312, and 316, to petitioner Praegitzer. Accordingly, under respondent's concession, our resolution of the dividend issue in petitioner Praegitzer's case renders the constructive dividend issue in petitioner Dawes' case moot. To reflect the foregoing as well as concessions by the parties, Decision will be entered under Rule 155 in docket No. 719-95. Decision will be entered for petitioner in docket No. 1344-95.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011