Respondent determined deficiencies in petitioners' income taxes for 1943 in the amounts of $108,159.53 and $4,592.78, respectively.
Because of the provisions of the Current Tax Payment Act of 1943 the year 1942 is also involved.
One of the issues raised in the petitions filed has been conceded by the petitioners. There remain two questions for our consideration: (1) Whether the Southern Fireproofing Company constituted a valid partnership between petitioners...