Memorandum Findings of Fact and Opinion
This case arises on respondent's determination of a deficiency in petitioner's unjust enrichment tax for the years 1935 and 1936, in the sums, respectively, of $767.23 and $1,450.41.
Two questions are raised, (1) Whether Title III of the Revenue Act of 1936, laying a tax on unjust enrichment, is unconstitutional; and (2) the questions, (a) whether a computation of the burden shifted by the taxpayer to others, made...
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