Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The respondent determined a deficiency of $12,874.25 in the federal income taxes of the petitioners for the calendar year 1968. Certain issues not having been raised in the petition, the sole issue for decision is whether petitioner Robert Trent Jones constructively received a dividend in the amount of $22,075 from International Planners Limited in 1968.
Findings of Fact
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