Memorandum Findings of Fact and Opinion
HARLAN, Judge:
Respondent determined a deficiency against Severin F. Blain in income tax for the taxable year 1943 in the amount of $8,181.22. The year 1942 is also involved because of the provisions of the Current Tax Payment Act of 1943. The sole issue presented is whether the sums of $25,071.62 and $9,751.68, paid to Severin F. Blain during the respective years 1942 and 1943 and being a portion of payments made...
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