Memorandum Findings of Fact and Opinion
KERN, Judge:
Respondent determined a deficiency in petitioners' income tax for the year 1954 in the amount of $8,817.02, resulting from his determination that petitioners received additional unreported ordinary income of $15,000 in that year from William Glick. Petitioners now argue that they received $15,000 from Glick in 1954 but contend that this sum is taxable as a longterm capital gain.
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