Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $19,036.94 in the petitioner's income tax for the calendar year 1941. The sole issue is whether the Commissioner erred in holding that the net income from a business conducted under the trade name of the Bupane Gas Company for the eight months ended December 31, 1941, was taxable to the petitioner. The petitioner claims that the income in question was distributable between certain...
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