Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioners' Federal income tax for the calendar years 1967, 1968, and 1969, in the respective amounts of $116,004.75, $3,033.99, and $11,694. The issues for decision are: (1) whether at least $239,500 over which petitioners gained complete dominion and control in 1967 is properly includable in their gross income for that year; (2) whether, if petitioners...
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