Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the year 1953 in the amount of $3,226.40. The issues for decision are whether the cancellation of an indebtedness of one of the petitioners to the other stockholders of a corporation in which he was also a stockholder, occurred in 1953 as determined by respondent or in 1954 as contended by petitioners, and whether this cancellation of indebtedness...
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