Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent has determined deficiencies in petitioners' income tax for the taxable years 1958 and 1959 in the respective amounts of $50,437.82 and $211.57. Petitioners claim overpayments in income tax for the years 1958 and 1959 in the respective amounts of $6,000 and $23,074.
The issues for decision are:
(1) Whether certain of the payments received by Charles W. Balthrope, who will hereafter...
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