Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in the income tax of the petitioner of $1,807.45 for 1939, $8,671.66 for 1940, and $12,735.72 for 1941. He also determined an additional 25 per cent, or $451.86, for 1939 under section 291(a) because the return for that year was not filed on time. The petitioner assigns as error the action of the Commissioner in failing to recognize that the petitioner's wife was his partner and entitled...
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