Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined deficiencies in petitioners' 1977 and 1978 Federal income taxes in the amounts of $522 and $517, respectively. After concessions, the issues for decision are whether petitioners received constructive dividends from their personal use of automobiles owned by their closely held corporation and, if so, the amount of such dividends.
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