Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $4,704.02 in income and victory tax for 1943 and deficiencies of $965.88 for 1944 and $2,886.80 for 1945 in income tax of the petitioner. The only issue for decision is whether the Commissioner erred in taxing 75 per cent of the income from a celery farm to the petitioner instead of 50 per cent.
Findings of Fact
The petitioner filed his individual income tax returns...
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