Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
The Commissioner determined a deficiency of $15,371.06 in petitioner's income and victory tax for 1943 and a deficiency of $17,317.66 in his income tax for 1944, in part by adding to income reported 20 per cent of the profits of a partnership which were distributable to his wife under the terms of a partnership agreement. Petitioner contests the determination that the wife is not recognizable as a partner...
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