Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $2,455.03 in income tax for 1940. The taxpayer contends that certain income received in 1940 should be allocated under Section 107 over the period 1930-1940, inclusive, instead of 1931-1939, inclusive, as the Commissioner determined.
Findings of Fact
The taxpayer, an individual of Washington, D. C., filed a joint return for 1940 for himself and his wife in the District...
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