Memorandum Findings of Fact and Opinion
By this proceeding, petitioner contests respondent's determination of a deficiency in income tax for the year 1943 in the amount of $1,135.92, and claims overpayment of such tax. The year 1942 is also involved by reason of the provisions of the Current Tax Payment Act of 1943.
Two issues are presented. The first is the propriety of respondent's determination that of the amount of $18,000 paid in each year by petitioner...
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