Memorandum Findings of Fact and Opinion
In these proceedings, consolidated for trial and opinion, the respondent has determined deficiencies in the Federal income tax of each petitioner for the year 1946 in the amount of $2,877.33. Some of the issues raised by the pleadings herein have been settled by stipulation. The issues remaining for our decision are: (1) whether payments received in 1946 by a partnership composed of the petitioners, pursuant to yacht charter...
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