Memorandum Findings of Fact and Opinion
PIERCE, Judge:
Respondent determined a deficiency for the year 1955 in the income tax liability of the petitioners in the amount of $8,856.80.
The sole issue to be decided is whether payments aggregating $22,916.63 received by Frances C. Cross in the taxable year from a corporation of which her deceased husband had been president and a director at
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