Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Petitioners contest the following deficiencies in income tax determined by respondent:
Year Amount Arthur E. Moreton ............ 1947 $51,749.48 Arthur E. Moreton and Ethel T. Moreton .................. 1948 58,581.89
The sole question for decision is whether the sum of $250,000 of which petitioners received...
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