Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined a deficiency in the income tax of petitioners for the year 1958 in the amount of $19,017.03, and an addition to tax under section 6653(a) of the Internal Revenue Code of 1954 in the amount of $950.85.
The deficiencies in question resulted from a written agreement dated June 6, 1958, whereby petitioners received $15,000 in notes, later paid in full, and certain machinery and...
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