Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency of $13,365.38 in petitioner's consolidated Federal income tax return for the taxable year ending December 31, 1970. There are two issues for our resolution. We must decide whether petitioner's subsidiary, Porter Rodgers Hospital, Inc., whose income was reported on petitioner's 1970 consolidated Federal income tax return, recognized income when debts owed by the subsidiary...
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