Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined deficiencies in income tax against petitioner in the amount of $119,853.53 for 1944; $136,920.12 for 1945; and $109,163.93 for 1946. The sole issue is whether a trust created by petitioner in 1942 was, for income tax purposes, a bona fide member of a partnership of which petitioner was a member. Petitioner filed income tax returns for the calendar years 1944, 1945 and 1946 with...
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