Memorandum Findings of Fact and Opinion
These proceedings were brought to test the correctness of the respondent's determinations of deficiencies in income tax for the years 1946 and 1947. There has been determined against each of the petitioners a deficiency of $1,402.53 for 1946 and a deficiency of $4,325.29 against each petitioner for 1947. Two issues are involved: (1) the validity of a partnership, and (2) the deductibility of a storm and flood loss and the...
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