FORRESTER, Judge:
Respondent has determined deficiencies in petitioner's Federal income tax for the taxable years ending January 31, 1966, and January 31, 1967, in the amounts of $97,514.85 and $83,150.54, respectively.
Concessions having been made, the only issue remaining for decision is whether funds received by the Ford Dealers Advertising Fund, Inc., from its members and Ford Motor Co. are includable in "gross income."
FINDINGS OF FACT...
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