Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency in income tax against the petitioners for the taxable year 1958 in the amount of $39,276.68, together with an addition to tax of $99.08 under section 6654 of the Internal Revenue Code of 1954 for underpayment of estimated tax.
The issues presented are whether the petitioner E. Wheeler Bryant realized taxable income, as compensation for services, of $55,897...
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