OPINION The first issue is whether W. B. and Mozelle Rushing received constructive dividends of'$62,892.40 in 1962 and $2,900 in 1963. Respondent’s position is that petitioners constructively received these amounts when L.C.B. advanced such amounts to Briercroft. Respondent premises his argument on the theory that the advances should be treated as contributions to capital rather than bona fide debt. <p "…
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