Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
Respondent has determined income tax deficiencies and penalties for petitioner as follows:
Year Deficiency Penalty 1942 .......... $ 2,517.58 $ 1,258.79 1943 .......... 282,937.09 141,468.55
The first and principal issue is whether petitioner was a partner in the operation of three liquor stores. The second, and an issue depending upon...
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