Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
These proceedings, consolidated for hearing, involve deficiencies in income tax and a penalty as follows:
Docket No. Year Deficiency 25% penalty 25643 1946 $655.33 25644 1947 615.00 153.75
The issues are (1) whether petitioner received taxable income under section 22(a), Internal Revenue Code; (2) whether the amounts as determined by respondent...
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