Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent has determined income tax deficiencies against the petitioner for the years 1936 and 1937 in the respective amounts of $6,160.65 and $6,250.46. The sole question presented is whether the petitioner is liable on 75 percent or 50 percent of the net income of the partnership of Outwater, Schwerin and Barnet for the years 1936 and 1937.
Findings of Fact
The petitioner is...
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