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KENT v. COMMISSIONER

Docket No. 9352.

6 T.C.M. 429 (1947)

William R. Kent v. Commissioner.

United States Tax Court.

Entered April 25, 1947.

Attorney(s) appearing for the Case

Lewis Donelson, III, Esq., and Allan Davis, Esq., 1224 Commerce Title Bldg., Memphis, Tenn., for the petitioner. John R. Stivers, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

By this proceeding petitioner seeks a redetermination of deficiencies for the years 1940 and 1941, in the respective amounts of $6,030.44 and $57,142.02.

The primary issue is the correctness of respondent's action in taxing petitioner upon partnership income which petitioner contends should be attributed to participating interests in the partnerships...

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