IRWIN, Judge:
By letter dated December 13, 1977, respondent determined deficiencies in petitioners' 1974 and 1975 income taxes of $1,237 and $3,005, respectively. The only issue for our decision is whether payments of premiums on certain policies insuring the life of petitioner, Howard Johnson, by a corporation in which petitioners are shareholders, constitute income to petitioners.
FINDINGS OF FACT
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