Respondent determined a deficiency in income tax against petitioners for the calendar year 1949 in the amount of $5,441.77. The only issue to be decided is whether $32,000 received by petitioner Harold L. Ward in the taxable year for services rendered by him in 1941, 1942, 1943, and 1944 as president of the Ward Redwood Company, Inc., falls within the ambit of section 107 (a) or 107 (d) of the Internal Revenue Code of 1939.
FINDINGS OF FACT.
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