Memorandum Findings of Fact and Opinion
TRAIN, Judge:
The respondent determined deficiencies in petitioner's income tax for the years 1959 and 1960 in the respective amounts of $332.47 and $216.92.
The sole issue for decision is whether respondent erred in taxing to petitioner as community income one-half of the income distributed to her ex-husband by a partnership during the period prior to the entry of a final judgment in their divorce action....
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