Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1964 in the amount of $1,168.73.
Some of the issues raised by the pleadings have been disposed of by the parties, leaving for our decision the following:
(1) Whether respondent is collaterally estopped by the decision in Sherar v. United States, an...
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