Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
The respondent determined a deficiency in petitioners' income tax for the year 1960 in the amount of $1,516.11. The only issue remaining is whether a $7,500 payment made to the petitioners in 1960 constituted ordinary income to them.
Findings of Fact
The petitioners, individual taxpayers, residing in New York City, filed a joint return for the year 1960 with the district director...
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