Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in the petitioner's income tax of $642.83 for 1961 and $31,219.86 for 1962. "The only issue for determination is whether petitioner's share of the distributable income of Intermountain Electric, Inc., (a small business corporation electing to be taxed as a partnership) for the taxable year ended October 31, 1962, should be increased by $47,121.25."
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