Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1973 in the amount of $50,508.17. The sole issue for decision is whether payments of deferred compensation in the amount of $70,777.52 constitute gross income to the petitioners in the taxable year 1973, the year in which petitioner John Gambling received such payments or whether they were constructively received...
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