Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $74,041.72 in income tax for 1947. The issues for decision are whether income of a partnership is taxable to the petitioner instead of to his wife and whether a loan to his brother and wife became worthless in 1947.
Findings of Fact
The petitioner filed his individual return for 1947 with the collector of internal...
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