
    Louise R. Braunstein, Petitioner, v. Commissioner of Internal Revenue, Respondent.
    Docket No. 13776.
    Promulgated July 16, 1929.
    
      John G. Hermann, Esg., for the petitioner.
    
      Paul Peyton, Esg., for the respondent.
   OPINION.

Littleton:

Upon the facts disclosed by the record, we are of opinion that the dividends in question in this proceeding were not unqualifiedly subject to the demand- of petitioner in 1923 and that she, therefore, properly reported the amount thereof as income for 1924. Robert W. Bingham, 8 B. T. A. 603; A. E. Potter, 10 B. T. A. 563; Emily D. Proctor, 11 B. T. A. 235.

Judgment will be entered under Rule 50.  