Memorandum Opinion
VAN FOSSAN, Judge:
The respondent determined a deficiency of $17,946.41 in petitioner's income tax for the year 1945, consequent chiefly on his holding that "The partnership of Waverly, Sayre and Athens Transportation Co. * * * is not recognized for Federal income tax purposes * * *."
[The Facts]
Petitioner is an individual who resides at Odessa, New York, and filed his individual income tax return for the year...
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