Respondent has determined deficiencies in petitioners' Federal income tax for the taxable years ending June 30, 1968, and June 30, 1969, in the amounts of $126,083.88 and $77,781.32, respectively. Various concessions having been made, the issues remaining for our decision are whether the transfer of escrow instructions No. 54593-C to Decon Corp. by its president was a sham and should be ignored for income...
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