Memorandum Findings of Fact and Opinion
DISNEY, Judge:
The Commissioner determined a deficiency in income tax for 1940 and 1941 in the amounts of $14,886.16 and $38,398.34, respectively.
The issue is whether the Commissioner properly determined that all of the net income of the alleged partnership of William A. Reynolds & Co. is taxable to petitioner, William A. Reynolds, for the years 1940 and 1941.
A stipulation of facts was filed....
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