Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency in income tax of $7,186.42, and an addition thereto of $1,796.61 for failure to make and file a return, for the taxable year 1950.
The petitioners contend: (1) that, except for an amount less than $600, their entire income was excludable from gross income under section 116(a)(1), Internal Revenue Code of 1939, and therefore they were not required to file a return; (2) that...
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