Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in petitioner's income tax for 1953 in the amount of $8,719.23.
The issue for decision is whether respondent erred in including in petitioner's 1953 income the amount of $12,284.97 which had been credited to his account on the books of a corporation of which he was president and a substantial stockholder.
Findings of Fact
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