Memorandum Opinion
VAN FOSSAN, Judge:
The respondent determined a deficiency of $5,803.54 in income tax for the year 1939, of which $5,550.53 is stated to be in controversy.
[The Facts]
The petitioners filed a joint return as husband and wife but since the issue in the case involves only Alvin H. Phillips, in this report he will be referred to as the petitioner.
Alvin H. Phillips, Inc., is a corporation organized in 1917...
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