Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $91,826.58 in Petitioner Pauline R. Grow's 1978 Federal income taxes and of $1,507 in Petitioners John Grow and Arunee Grow's 1978 Federal income taxes. After concessions by petitioners, the issue remaining for decision in these consolidated cases is how much of the purchase price received by petitioners' wholly-owned subchapter S corporation from the sale of some...
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