Memorandum Opinion
SMITH, Judge:
This proceeding involves a deficiency of $2,239.69 in petitioner's income tax for 1938. The only question for our determination is whether the income from a fractional interest in an oil and gas lease is taxable to petitioner or to his wife.
[The Facts]
Petitioner is a resident of Kansas City, Kansas. The record does not show where his income tax return for 1938 was filed.
Petitioner purchased...
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