OPINION
STERRETT, Judge:
The respondent determined a deficiency of $4,152 in the petitioner's Federal income tax for the calendar year 1971. Certain issues not having been raised in the petition, the sole issue presented requires our determination of the amount of income petitioner must report in 1971 as a result of his being a stockholder of Sure Quality Framing Contractors, Inc., an electing small business corporation.
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