This proceeding was heard on petitioners' motion to dismiss for lack of jurisdiction. Respondent determined a deficiency in income tax of petitioners for the calendar year 1948 in the amount of $199. The parties have stipulated that if the Court determines it has jurisdiction it may enter its order that there is a deficiency in Federal income tax due from petitioners for the taxable year 1948 in the amount of $99.
FINDINGS OF FACT.
All the facts were stipulated...
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