Memorandum Opinion
JOHNSON, Judge:
The respondent determined a deficiency in petitioner's income tax for the year 1945 in the amount of $11,608.79.
Petitioner is a resident of Memphis, Tennessee, and filed his income tax return for the year 1945 with the collector of internal revenue for the western district of Tennessee.
The only issue here presented is whether respondent in his notice of deficiency erred in holding that petitioner's wife...
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