Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding involves a deficiency of $11,429.83 for the calendar year 1941. The only issue involved is whether the business carried on under the name of David O. Davis & Son was a valid partnership for Federal income tax purposes. The case was submitted upon a stipulation of facts, oral testimony and exhibits. The facts stipulated are so found. Other facts are found from the record.
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