Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner has determined deficiencies in the income tax liability of the petitioners for the year 1943 as follows:
Docket No. 22206 ............ $6,601.03 Docket No. 22207 ............ 6,601.04
These proceedings have been consolidated for trial and opinion.
The issue in these proceedings is whether or not John and Myrtle Rossi constructively received income...
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