Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $12,032 in petitioners' income tax for the calendar year 1968. The parties have reached an agreement in respect of each of the matters raised in the deficiency notice, leaving for decision only the propriety of the Commissioner's disallowance of petitioners' refund claim relating to the same taxable year. At issue is a single factual question: at the time it was made, what was the...
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