Memorandum Findings of Fact and Opinion
GERBER, Judge:
By notice of deficiency dated April 8, 1986, respondent determined a deficiency of $19,807 in petitioners' Federal income tax for the calendar year 1982. The sole issue for decision is whether petitioners must include in gross income $45,000 received by petitioner-husband and paid over to a newly formed corporation.
Findings of Fact
Some of the facts have been stipulated and are incorporated...
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