Memorandum Findings of Fact and Opinion
The respondent determined deficiencies of $350,615.48 and $235,961.22 in petitioners' income tax for the years 1943 and 1944, respectively. As a result of the Current Tax Payment Act, the year 1942 is also involved. Hereinafter Leo N. Donati is sometimes referred to as the petitioner.
The sole question involved is whether, for the taxable year, the Fibre Board Container Company was a valid and bona fide partnership...
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