Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in the Federal income tax of petitioners for the taxable year 1965 in the amount of $46,246.67. The only issues presented for our consideration are whether a transfer by McLemore Realty Company, Inc., ("Realty") of $60,000 to Clark County Motors, Inc., ("Motors") on April 1, 1965, and/or an advance of $33,000 by Realty to petitioner Robert W. McLemore on April 1, 1965...
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