Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined for the calendar year 1959 a deficiency in petitioner's income tax in the amount of $5,343.94 and a delinquency penalty under section 6651(a) of the 1954 Code in the amount of $1,335.99. The only issue for our decision is whether or not petitioner was a partner during the taxable year with her then husband, Aaron Liebesman, in the operation of a department store business so that a...
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