Memorandum Findings of Fact and Opinion
ARUNDELL, Judge:
Respondent determined deficiencies in income tax for the years 1949 and 1950 in the amounts of $4,222.24 and $18,367.30, respectively. Petitioners claim overpayments for both years.
The issues remaining for decision are: (1) Whether certain amounts (both lump sum and gallonage payments), received by "first party" G. R. Gowdey, now deceased, during the taxable years 1949 and 1950 from the "second...
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