Memorandum Opinion
MULRONEY, Judge:
The respondent determined a deficiency in petitioners' 1958 income tax in the amount of $1,240.98. The issue is whether petitioner James S. Price, a cash basis taxpayer, constructively received an item of $5,000 income in 1958.
All of the facts are stipulated and are found accordingly.
James S. Price, hereinafter referred to as petitioner, and his wife, Mae D. Price, filed their joint income tax return...
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