Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioner's Federal income tax for the taxable year 1970 in the amount of $24,172.99. Concessions having been made, the sole issue for decision is whether petitioner received, either actually or constructively, a check in the amount of $19,000, dated December 30, 1970, from the Landmark Hotel during the taxable year 1970.
Findings of Fact
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