Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding arises out of respondent's determination that deficiencies in income tax are owing for 1945 of $5,277.75 by Sam Newman, $5,524.37 by Moe Newman, $1,984.68 by Joseph Sassower, $4,321.30 by Jacob S. Hausman, and $4,169.61 by Jacob Miller. Certain adjustments are not contested. The sole issue is whether respondent properly taxed to petitioners the income of two business enterprises, of which...
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