Memorandum Findings of Fact and Opinion
The respondent has determined a deficiency of $12,917.27 in petitioner's income tax for 1941. The sole issue is whether the petitioner is taxable on the gain on the sale of certain machine tools which he allegedly transferred to his wife as a gift just prior to their sale.
Findings of Fact
The petitioner is a resident of Rochester, New York. He filed his income tax return for 1941 with the collector of internal...
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