Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined a deficiency in petitioner's income tax for the year 1947 of $4,753.37. The only issue for decision is whether that part of the payment of 50 per cent of the profits of a business received by petitioner on December 10, 1947, subsequent to the effective date of the Nebraska community property law, was community property or separate property.
The petitioner proportioned...
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