Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $3,551.23 in petitioner's income tax for its taxable year ended April 30, 1964. The sole issue for our determination is whether petitioner should be treated as having realized $12,982.00 in additional rental income, representing the excess of rent received from a sublessee by petitioner's sister corporation, which leased and operated a theater owned by petitioner...
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