Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax of $7,504.96 determined against Carrie C. Cunningham (hereinafter referred to as the petitioner) for the year 1947. By amended answer, respondent now asserts such deficiency is $8,933.78.
The issues to be decided are: (1) did petitioner, by virtue of a sales contract executed in 1947 transferring a going florist business, owned by her, to others, but retaining title...
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