Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined deficiencies of $35,871.54 and $44,631.99 in petitioners' Federal income taxes for 1972 and 1973, respectively.
The sole issue for decision is whether all of the taxable income of North East Optical Service, Inc., for its fiscal years ended March 31, 1972 and March 31, 1973, is attributable to petitioners and should be included in their gross income for calendar years 1972...
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