Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined a deficiency in petitioners' 1980 income tax in the amount of $16,922. By an amendment to his answer, respondent increased the deficiency to $110,890.25.
After concessions, the remaining issues are (1) whether petitioner husband received a constructive distribution of $498,450.81 upon the foreclosure sale of property owned by a subchapter S corporation in which he was the...
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