Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax of petitioner for the year 1952 in the amount of $1,329.23.
The sole issue is whether petitioner is entitled to the benefits of section 107(a) of the Internal Revenue Code of 1939.
Findings of Fact
The stipulated facts are found accordingly.
Petitioner, since 1895, has been a duly licensed...
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