Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $3,553.07 in the income tax of the petitioner for 1944. The only issue is whether the Commissioner erred in refusing to recognize five trusts as limited partners and in taxing their distributive shares of the partnership income to the petitioner.
Findings of Fact
The petitioner filed his individual return for 1944 with the collector of internal revenue for the first...
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