TRAIN, Judge:
Respondent determined a deficiency in petitioners' income tax for the taxable year ended May 31, 1959, in the amount of $218,990.05. Petitioners' initial objection that respondent's action is barred by the statute of limitations was conceded by them in the reply brief. The parties agree that the only issue remaining for decision is whether a payment by petitioner Ray McGlothlin of the sum of $261,968.74 to Texas Calgary Co. during the taxable...
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