Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency of $66,244.28 in petitioners' Federal income tax for 1969. Other issues having been conceded by petitioners, the only one remaining for decision is whether G-O Enterprises, Inc., a corporation in which petitioner John R. Ozier was a shareholder, was eligible under sections 1371 and 1372
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