Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiences in petitioners' income taxes for the calendar years 1966 and 1967 in the amounts of $4,732.11 and $3,385.45, respectively.
One of the issues raised by the pleadings has been conceded by petitioners, leaving for our decision whether a corporation of which one of petitioners was the sole shareholder filed a timely election under section 1372(c)(1), I. R. C. 1954...
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