Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding involves deficiencies in income taxes for the years 1939 and 1940 in the amounts of $6,247.44 and $14,621.93 respectively. The sole issue is, whether during the taxable years there existed a valid partnership recognizable for income tax purposes between the petitioner and his son, William J. Sweigard.
The case was submitted upon a stipulation of facts, oral testimony and exhibits...
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