Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined deficiencies in petitioners' joint Federal income taxes for calendar years 1977, 1978, and 1979 in the amounts of $20,600.58, $14,142.74, and $15,144.61, respectively. The issue presented for determination is whether the income attributable to petitioner John L. Fatland's medical practice is taxable to him instead of his wholly owned professional corporation...
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