Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a deficiency in petitioners' Federal income taxes for the taxable year 1981 of $8,336. The deficiency resulted from respondent's determination that Kent Video Tape and Disc, Ltd. ("Kent"), a corporation in which petitioners were shareholders, was not an electing small business corporation as defined in section 1371(b)
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