Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $7,903.53 in income tax for 1940, denying the application of Section 107 of the Internal Revenue Code.
Findings of Fact
Petitioner, a resident of Toledo, Ohio, filed his return for 1940 on a cash basis in the Tenth District of Ohio.
He has been in the employ of The France Stone Company of Toledo, Ohio, since 1912; as general manager from 1929 to 1932, and...
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