Respondent determined a deficiency in income tax of petitioner for the year 1958 in the amount of $491,524.10.
The sole question for decision is whether income in the amount of $549,876.89 distributed by a Cuban joint farming venture in 1958 to Ainsley Associates, S.A., a Panamanian corporation, is includable in the income for that year of petitioner, its sole stockholder.
FINDINGS OF FACT
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