Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in 1944 income tax of $5,451.88 and a negligence penalty for that year amounting to $272.59. The deficiency results from respondent's determination that petitioner and his wife were not engaged in business as partners in 1944. Both the deficiency and the penalty are contested.
Findings of Fact
Petitioner is a resident of Philadelphia, Pennsylvania. His income tax return...
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