Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
This proceeding is again before us pursuant to remand from the Court of Appeals for the Ninth Circuit,
The respondent originally determined deficiencies in income tax for 1949 against Jack Showell in the amount of $3,946.65 and against Dorothy Showell in the amount of $4,065.69, based upon a determination that each...
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