Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined a deficiency in income tax for the year ending December 31, 1945, in the amount of $5,824.88. The three issues for decision are: (1) Did the Commissioner err in determining that the petitioner's wife, Lilyan Isabel Beels, could not be recognized as a partner for tax purposes, and that alleged partnership income reported by her is taxable to the petitioner? (2) Did the...
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