Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Resondent determined a deficiency of income tax of $10,227.04 against the petitioners for the calendar year 1977. The sole issue which we must decide is whether petitioner Robert J. Terris received a dividend in the year 1977 from a corporation in which he was a shareholder, and, if so, the amount thereof.
Some of the facts were stipulated, and such stipulation...
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