*1331OPINION.
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.