The Commissioner has determined a deficiency of $4,379.33 in petitioner's income tax for the year 1944. The deficiency is due to the action of the Commissioner in adding to the net income as disclosed by petitioner's return additional income of $7,833.43 designated as partnership income. This adjustment is explained in the deficiency notice as follows:
(a) It is held that your correct distributive share of the net income of the partnership of F. A. Marsily & Co...
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