Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in petitioner's income tax for 1947 in the amount of $73.26. Petitioner does not contest the adjustments on which the deficiency is based, but claims an overpayment in the amount of $469.90 as a result of his erroneous inclusion in gross income of the sum of $2,040. The single issue presented, therefore, is whether the monthly payments in the total amount of $2,040, received by petitioner...
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