Memorandum Findings of Fact and Opinion
HILL, Judge:
Respondent determined a deficiency in petitioner's income tax liability for the year 1941 in the amount of $18,681.55. The question presented is whether petitioner rather than his wife and daughter is taxable as a partner on 60 per cent of a certain partnership's income. Petitioner filed his income tax return with the collector of internal revenue for the district of Michigan at Detroit. The record consists...
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