HALL, Judge:
Respondent determined a deficiency of $3,792.39 in Eugene and Mary Kirk's income tax for 1972. Eugene Kirk died on October 4, 1976, and pursuant to an order of this Court dated September 13, 1977, his estate was substituted as a party. The sole issue for decision is whether a distribution of $7,157.03 by Music City Songcrafters, Inc., to Eugene Kirk on November 11, 1972, was taxable to him. That corporation's subchapter S election was terminated...
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