FISHER, Judge:
The respondent has determined a deficiency in petitioners' income tax for the year 1952 of $66,817.10. In the determination of the deficiency, the respondent stated in his deficiency notice as follows: "It is determined that you constructively received income of $91,692.24 which should have been reported on your income tax return for 1952, rather than 1953."
The sole question presented is whether Basil F. Basila, one of the petitioners...
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