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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.
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