Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax of the petitioners for the years 1952 and 1953 in the amounts of $22,550.25 and $4,005.66, respectively. The primary issue is whether petitioner is entitled to the benefit of section 107(a) of the Internal Revenue Code of 1939 with respect to informer's fees received in those years. By amendment to...
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