Memorandum Findings of Fact and Opinion
FISHER, Judge:
Respondent determined a deficiency in income tax of petitioners for the year 1954 in the amount of $4,734.84. The questions for our decision are whether one-half of dealer reserves released in 1954 by the Michigan National Bank constitutes income to petitioners in 1954 which was not reported in their gross income for that year and, if so, whether this amount is in excess of 25 percent of the gross income...
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