Memorandum Findings of Fact and Opinion
This proceeding was initiated to test the correctness of respondent's determination of a deficiency in the amount of $4,002.53 for the calendar year 1945. The major issue is the amount of petitioners' gross income from the operation of a tavern. Respondent concedes that should petitioners prevail on the major issue they will be entitled to a refund in the amount of $266.50 which represents an overpayment of their 1944 tax...
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