Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1964 in the amount of $214,893.09.
One of the issues raised by the pleadings has been conceded by petitioners, leaving for our decision the following:
(1) Whether the partnership income from a joint venture, Wilder Manor Co., credited to a corporation formed by petitioners, Sanford Building, Inc., was properly...
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