Memorandum Opinion
VAN FOSSAN, Judge:
The respondent determined deficiencies in petitioner's income tax for 1940 and 1941 in the respective amounts of $5,875.28 and $17,889.10.
The sole question presented is whether a partnership existed during the taxable years between petitioner and his two sons, Meyer and David Supornick.
The facts are as follows:
[The Facts]
The petitioner, now 60 years of age, resides in St....
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