Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined a deficiency in petitioners' income tax for 1961 in the amount of $64,543.74, as well as an addition to tax under section 6653(a) of the Internal Revenue Code of 1954,
As a result of concessions by both parties, the only issue remaining for our determination is whether petitioner received...
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