Memorandum Findings of Fact and Opinion
These proceedings involve deficiencies in petitioners' income taxes for 1943 in the following amounts:
Thomas R. Simmons ............$ 5,327.98 William P. Simmons ........... 5,566.66 D. R. Simmons ................ 18,647.53 Jack W. Simmons .............. 25,475.23
The single question in issue is whether petitioners are taxable on all of the income of two partnerships known as Simmons Brothers...
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