Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in the income tax of petitioner for the year 1947 in the amount of $43,525.16, plus an addition to tax for fraud in the amount of $21,762.58.
The issues are: (1) Did the respondent err in his determination that the petitioner received income in 1947, in connection with used-car sales of Erwin Chevrolet, Inc. and R. A. Erwin Motor Co., Inc., which he failed to report on his income...
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