Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined a deficiency in the income taxes of the petitioners for each of the calendar years 1952 and 1953, in the respective amounts of $2,378.03 and $337.38.
The issues presented for decision are:
(1) Whether petitioner Malcolm J. Morison, Jr., realized income in 1952, as the result of transactions between him and his controlled corporation wherein: (1) The corporation...
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