Memorandum Opinion
KÖRNER, Judge:
Respondent determined a deficiency of $10,511.05 in petitioners' 1978 Federal income tax. After concessions, the sole issue for decision (as presented by the parties) is whether petitioners received $21,000 of dividend income during 1978 which they failed to report on their return.
This case was submitted fully stipulated pursuant to Rule 122.
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