Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding seeks redetermination of deficiencies in petitioner's income tax of $67,011.76 and $415,543.77 for the years 1940 and 1941, respectively.
The primary issue remaining for decision is whether the entire income of a business is taxable to petitioner, or whether parts thereof are attributable to various members of an alleged partnership.
Findings of Fact
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