Memorandum Findings of Fact and Opinion
This case involves a deficiency in income tax for the calendar year 1940 in the amount of $664.02. Petitioners claim an overpayment. Three questions are presented: (1) Whether petitioners are entitled to file separate returns as citizens of Texas, a community property state; (2) Whether the amounts paid for rental of hotel rooms in New York City are deductible as ordinary and necessary business expenses; and (3) Whether petitioners...
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