Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent determined a deficiency in the income tax liability of the petitioners for 1961 in the amount of $7,383.67. The sole issue is whether $38,281.38 received by petitioner George A. Dean in that year was compensation for services or consideration for the transfer of property.
The petitioners, husband and wife, resided in Shawnee Mission, Kansas, during the taxable year in issue and...
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