Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $5,713 and $478,727 in petitioners' Federal income taxes for 1979 and 1980, respectively. After concessions, the issue for determination is whether petitioners received taxable income of $689,055 during 1980 by reason of forgiveness of a debt owed to their wholly owned corporation.
Findings of Fact
Some of the facts have been stipulated, and the...
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