The Commissioner determined a deficiency in petitioners' income tax for the year 1963 in the amount of $5,466.37, all of which is in dispute in these proceedings. The sole issue is whether petitioner George M. Breidert constructively received executor's fees of $9,100.20 in 1963.
FINDINGS OF FACT
Some of the facts have been stipulated, and, as stipulated, are incorporated herein by this reference along with accompanying exhibits.
George M. Breidert...
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