Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The respondent determined a deficiency in the Federal income tax of the petitioner of $3,187.78 for his taxable year ending December 31, 1966.
We have before us three issues for consideration. First, we are to determine whether petitioner, during the calendar year 1966, actually or constructively, received rental income in the amount of $11,154.32. This requires us to determine if the transaction...
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