Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent determined deficiencies in income tax for the calendar years 1954 and 1955 in the respective amounts of $1,968.02 and $628.26.
The principal issue is whether an oral agreement between the petitioner and Dr. Herbert M. LaRue was in the nature of a joint venture with a division of fees or amounted to the sale by the petitioner to LaRue of an existing practice. If held to be a sale...
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