OPINION.
OPPER, Judge:
The deficiencies in issue are for income tax in the respective amounts of $5,388.96 for the year 1943 in Docket No. 23432 and $3,001.64 for the year 1945 in Docket No. 23433. Petitioner claims an overpayment. The issue in each of the consolidated proceedings is whether petitioner, as a member of a law partnership, is entitled to apply section 107, Internal Revenue Code, so as to include in the time of the rendition of the services...
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