*2532 There is no evidence to show that the amounts covered by dividend checks issued in 1922 were not unqualifiedly subject to petitioner's demand in that year, and respondent's inclusion of them in income for that year is approved.
*1068 Petitioner seeks a redetermination of a deficiency in income tax in the amount of $732.12 for the year 1922. The question for decision is whether respondent erred in including in income the amount of certain dividend checks issued on the last day of the year.
FINDINGS OF FACT.
Petitioner, an individual, kept his books and made his income-tax return for 1922 on the cash receipts and disbursements basis.
Dividends reported by petitioner for 1922 and the amounts included in income by respondent are as follows:
| Issuing company | Reported | Adjusted by respondent |
| Toledo Furnace | $19,200 | $17,600.00 |
| Delft Theatres | 350 | 500.00 |
| Youngstown Sheet & Tube | 14,508 | 17,532.00 |
| Interlake Steamship | 3,000 | 3,187.50 |
| Total | 37,058 | 38,819.50 |
| Increase | 1,761.50 |
*1069 The adjustments made by the respondent arise out of the fact that the companies listed*2533 issued dividend checks on the last day of the year.
OPINION.
ARUNDELL: The foregoing facts have been found from the admissions contained in respondent's answer and a stipulation filed. No evidence was offered to show that the amounts covered by the dividend checks were not unqualifiedly subject to petitioner's demand in the year in which the respondent included them in income. See section 201(e), Revenue Act of 1921. The respondent's determination must accordingly be affirmed. Cf. ; .
Decision will be entered for the respondent.