Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax for the taxable years 1944 and 1945 in the amounts of $11,577.12 and $16,220.88, respectively. The sole issue is whether the Commissioner erred in failing to recognize petitioner's wife, daughter and son as members of a partnership with petitioner and in treating petitioner as a sole proprietor.
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