Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in the income tax of petitioner for the calendar year 1947 in the amount of $43,861.50 representing the tax on petitioner's $75,000 share of the profits on a transaction involving the purchase and sale of two war surplus landing ships. In computing the deficiency, no credit was given for $22,500 withheld at the source. Petitioner concedes his liability to the extent of that amount and respondent...
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