Respondent determined deficiencies in the income taxes of petitioners for the years 1948 and 1949 in the amounts of $10,383.86 and $2,678.60, respectively. By amended answer filed herein, respondent seeks to increase the deficiency for 1949 to $9,238.
The issues for decision are as follows:
1. Whether petitioners were required to treat as income in each taxable year the entire amount received in that year from two organizations formed under the laws of Venezuela...
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