Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioners assail respondent's determination of deficiencies in income tax for the calendar years 1945 and 1946 of $19,705.99 and $5,157.78, respectively, against petitioner Simon H. Strickler, and of $13,092.71 and $3,207.72, respectively, against petitioner Otto Cooper. Certain adjustments in the case of the former petitioner are not contested. The sole issue is whether respondent erred in taxing to...
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