Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined deficiencies in income tax against the petitioner for the calendar years 1948 and 1949 in the respective amounts of $141.15 and $154.90. The question presented is whether petitioner, a resident of Minnesota and separated from her husband prior to his going to California, is taxable on one-half of the income earned by her husband in California during the taxable years.
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