Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $18,983.55 in the petitioner's income tax liability for the calendar year 1945. Certain concessions were made by the petitioner leaving only the following issue: Whether respondent erred in taxing to petitioner all of the income of the Stephen Operating Company, an alleged joint venture or partnership between petitioner and his wife.
Findings of Fact
The petitioner...
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