The respondent determined deficiencies in income tax of the petitioner of $16,371.94 and $9,208.66 for the years 1944 and 1945, respectively. The sole issue arises from the holding by respondent that the income of the business operated under the name of Paradise Foods Co. did not constitute partnership income and was, therefore, all taxable to petitioner.
The respondent on brief concedes that:
Adequate testimony was presented at the trial from which the Court...
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