Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $2,047.01 in petitioners' income tax for the calendar year 1967. The sole issue is whether petitioners received a dividend from their wholly owned corporation equal to the fair market value of a bronze sculpture.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
Petitioners, husband and wife, were legal...
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