This proceeding involves deficiencies in income tax determined by respondent against Nellie Russo Linsenmeyer (hereinafter referred to as petitioner) for the taxable years 1947, 1948, and 1949 in the amounts of $756.26, $311.50, and $168.31, respectively. Petitioner has claimed overpayments in her tax for such years.
The sole issue to be decided is whether petitioner is taxable on one-half of the partnership income of the North Pole Distributing Company and one-seventh...
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