MEMORANDUM FINDINGS OF FACT AND OPINION
Respondent determined a deficiency of $44,375 in petitioners' Federal income tax for 1995.
The issues remaining for decision are:
(1) Did petitioner James R. Palmer (Mr. Palmer) constructively receive during 1995 $95,935 of compensation that he did not actually receive until after that year? We hold that he did.
(2) Was the $5,100 that Mr. Palmer received during 1995 with respect...