Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1972 in the amount of $6,813.64. Petitioners have conceded the correctness of one of respondent's adjustments in the notice of deficiency. The only issue we must decide is whether $68,606.92 received by petitioners from their subchapter S corporation is subject to the maximum tax limitations of section 1348 of the Internal...
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