Memorandum Opinion
DAWSON, Judge:
Respondent determined deficiencies in the Federal income taxes of petitioners as follows:
Petitioners Year Deficiency David and Ruth Iler .... 1972 $43,081.21 Russell W. and Betty R. Rankin ................ 1972 12,933.39
Petitioners have conceded certain adjustments. The only issue presented for decision is whether Iler Construction Company, a subchapter S corporation...
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