Memorandum Findings of Fact and Opinion
The respondent has determined deficiencies for the taxable year 1947 in the amounts of $2,507.23 and $2,592.72 against Leola J. Bell and David A. Bell, respectively. Separate returns were filed on a community property basis. The proceedings were consolidated for hearing and disposition. The principal issue is the amount of petitioner David A. Bell's distributable share of partnership income from the partnership of Morgan-Bell...
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