Memorandum Opinion
ARNOLD, Judge:
The respondent determined a deficiency of $1,038.58 in income and victory tax for 1943 and a penalty of $23.59 against each petitioner. The issue is whether income received in one year for services in the previous year is includable for tax purposes in the year in which earned or the year in which received.
[The Facts]
The petitioners are husband and wife. They filed separate income tax returns for...
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