The respondent determined a deficiency of $197,002.55 in the petitioners' income tax for the taxable year 1962 and an addition to tax under section 6653 (a) in the amount of $9,850.13.
The issues for decision are whether a $241,000 bank deposit placed in the petitioner's bank account was gross income to the petitioners or whether the petitioners held this money only as an agent for petitioner Robert...
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