SIMPSON, Judge:
The respondent determined deficiencies in the income tax of the petitioner, Zilkha & Sons, Inc. (Zilkha), of $19,268.66 for its taxable year ending November 30, 1960, and $21,598.65 for its taxable year ending November 30, 1961, and in the income tax of the petitioners, Jerome L. and Jane Stern (the Sterns), of $13,836.25 for the taxable year 1961. The only issue remaining for decision is whether certain payments received by Zilkha and by...
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