Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
This proceeding involves a deficiency of $4,122.84 in income tax for 1946. The issue is whether a joint venture existed between petitioner and his wife for an equal division of his distributive share of profits of a partnership in which he had an interest. Respondent concedes error in increasing petitioner's income by $202.05 for rent receipts.
Findings of Fact
Petitioner, and individual...
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