The respondent determined an income tax deficiency of $25,774.81 against petitioner for the calendar year 1937. Instead of the deficiency petitioner claims a refund of $43,791.48.
In the statement attached to the deficiency notice the respondent made two adjustments to petitioner's net income as disclosed by his 1937 income tax return. Adjustment (a) was labeled "Increase in income from former partnership $39,602.80" and was explained as follows:
(a) The entire...
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