Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in the petitioner's income taxes for the years 1945 and 1946 in the amounts of $139,187.58 and $42,742.66, respectively. The sole question presented is whether the petitioner is taxable upon 50 per cent of the income of a partnership during the years in question or whether the petitioner's wife and three sons were bona fide members of the partnership.
Findings of Fact
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