Respondent determined a deficiency in income tax for the calendar year 1947 in the amount of $2,906.29. Petitioners, husband and wife, filed a joint return for 1947 with the collector of internal revenue, Customhouse, New York, New York. Petitioner Carol F. Hall is a member of the partnership of Touche, Niven & Co., public accountants and auditors. The partnership's return of income, filed for its fiscal year ended September 30, 1947, reported an amount as ordinary income...
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