Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated December 4, 1978, respondent determined a deficiency of $5,736.80 in petitioners' Federal income tax for the taxable year 1974. The sole issue presented for decision in this case is whether certain payments received by petitioner Joseph J. Vitale from the P.J. Polinsky Construction Company during 1974 represent additional income to petitioners for that year.
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