OPINION
KÖRNER, Judge:
This case is before the Court on remand from the United States Court of Appeals for the Sixth Circuit. The circumstances are as follows.
Respondent issued his statutory notice of deficiency to petitioners for their calendar years 1975 through 1979. His principal determination for each year, and the only one which concerns us here, was that certain income, reported in the years in question by the Lucille A. Sampson...
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