FEATHERSTON, Judge:
Respondent determined a deficiency in petitioners' joint Federal income tax for 1963 in the amount of $2,829.54. The sole issue presented for decision is whether petitioners' wholly owned foreign corporation is to be disregarded for tax purposes.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulations and exhibits thereto are incorporated herein by this reference.
The petitioners...
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