Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent made the following determinations with respect to the petitioners' income tax:
Addition to Tax Year Deficiency Sec. 294(d) 1952 $5,916.22 ...... 1953 ......... $99.75
The adjustment for 1953 is not contested. The only issue for decision is whether $16,200 which was received by Idabelle during 1952 pursuant to a lease...
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