Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1966 in the amount of $563.
The issue for decision is whether sums paid by Americans Building Constitutionally (ABC), a trust, for services rendered are income of Raintree Foundation or are includable in petitioner's gross income for the calendar year 1966.
Findings of Fact
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