Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in the Federal income tax of Phillip R. and Frances B. Clark for the taxable year 1971 in the amount of $13,889.18.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties leaving for decision whether the sum of $16,779.16 received by Phillip R. Clark during the taxable year 1971 from a partnership was a guaranteed payment...
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