PER CURIAM.
Petitioners, husband and wife, invoke the jurisdiction conferred upon us by 26 U.S.C. § 7482 to review a determination of the Tax Court of the United States. The findings of fact and opinion of the court below are reported at
In 1961 the petitioning husband, hereinafter called taxpayer, was the sole owner of all the outstanding stock of Diablo Development Co., a California corporation. The corporation...
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