Memorandum Findings of Fact and Opinion
FISHER, Judge:
Respondent determined a deficiency in the income tax of petitioners for the taxable year 1954 in the amount of $3,093.72.
The principal issue for decision is whether respondent erred in including in petitioner Henry B. Bowen's 1954 income, the amount of $12,000 which had been credited to an account receivable in his name on the books of a corporation of which he was president and sole shareholder...
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