Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1972 and 1973 in the amounts of $20,744 and $46,563, respectively.
The issues for decision are as follows:
(1) Is James W. Gilmartin (petitioner) the owner of a film entitled "Moonchild" for Federal tax purposes;
(2) if the Court determines that petitioner is the owner of the film, did...
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