Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioner challenges respondent's determination of deficiencies in income tax for the years 1941 and 1943 of $1,393.68 and $3,689.05, respectively. The year 1942 is in question by reason of the Current Tax Payment Act. The only issue is whether amounts received by petitioner as rents on real property and as beneficiary of a trust are community income taxable one-half to petitioner...
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