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SMALL v. COMMISSIONER

Docket No. 48953.

13 T.C.M. 1155 (1954)

T. C. Memo. 1954-230

Henry G. Small v. Commissioner.

United States Tax Court.

Filed December 20, 1954.

Attorney(s) appearing for the Case

Kenneth W. Bergen, Esq., and Donald O. Smith, Esq., for the petitioner. Jack H. Calechman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined a deficiency in income tax of petitioner for the year 1948 in the amount of $941.26.

This proceeding is a companion case to Mary W. Conrad, Docket No. 41019, the opinion in which is handed down and filed simultaneously herewith. The cases were tried separately. The issues to be resolved here are: (1) Whether petitioner and Mary W. Small were partners for income tax purposes during the period January...

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