Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined a deficiency of income tax against petitioners in the amount of $599,352, relative to their taxable year ended December 31, 1975. By amended answer filed on June 25, 1984, respondent sought an additional deficiency of $530,002. After concessions, the sole issue remaining for decision is whether any part of the consideration received by petitioner James A. Patterson under an...
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