Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The respondent determined a deficiency of $2,401.36 in the petitioners' income tax for the year 1958 and $551.55 for the year 1960. The issues to be decided in this case are: (1) Whether the respondent acted arbitrarily in changing the acounting method used by the petitioner and in including in his gross income for 1958 the amount of $4,000 received in that year as payment for legal services to be rendered...
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