Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in the income tax of petitioner in the amounts of $8,634.08 for the year 1940 and $37,266.35 for the year 1941.
The sole question is whether the respondent erred in determining that there was no valid partnership between petitioner and his wife during the taxable years and that the entire net income from a business conducted under the name of the City Sales Company was includible...
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