Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined deficiencies in the petitioners' income tax for the years 1955 and 1956 in the amounts of $278.33 and $4,835.30, respectively. The issues are (1) whether petitioners are entitled to attribute a $4,200 fee received in 1955 to prior years under section 1301 of the Internal Revenue Code of 1954;
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