Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $37,785 in petitioners' Federal income tax for 1989. After concessions by the parties, the sole issue for decision is whether petitioners are liable for tax on constructive receipt of rental income from their wholly owned real estate corporation in the amount of $9,000.
Unless otherwise indicated, all section references are to the Internal Revenue Code in...
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