Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in petitioner's income taxes as follows:
1938 ............. $102.82 1939 ............. 507.64 1940 ............. 808.43 1941 ............. 5,684.68
The sole issue is whether earnings and profits of the Zippo Manufacturing Company (a partnership), reported as distributable to petitioner's wife, are taxable to the petitioner "as the real owner...
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