Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined a deficiency in income tax for 1947 in the amount of $3,721.41 against each of the petitioners. The whole amount of the deficiencies is not in controversy since the petitioners have agreed to assessment of a part thereof. Two issues are presented: (1) Whether a portion of the income of a partnership, A. D. Gugenheim Company, during its fiscal year ended June 30, 1947, is taxable...
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