Memorandum Findings of Fact and Opinion
This proceeding involves deficiencies in the petitioner's income tax for the years 1943 and 1944 in the amounts of $7,343.94 and $597.89, respectively. The year 1942 is involved by reason of the forgiveness feature of the Current Tax Payment Act of 1943.
There are two questions presented for our determination: First, whether a payment of $19,200 which petitioner received in 1942 from his employer corporation whose...
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