DAWSON, Judge:
Respondent determined a deficiency of $3,499.44 in the income taxes of petitioners for the year 1962.
Although petitioners placed the entire deficiency in dispute, they failed to allege error as to certain minor adjustments. Consequently, such matters are not in controversy. The only issue for decision is whether a distribution of $19,125.30 to petitioner, Victor S. Gittens, on March 31, 1962, of his entire interest in the Philco Corp...
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