Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined income tax deficiencies for the calendar years of 1939 and 1940 of $364.59 and $7,369.46, respectively. The deficiencies resulted from respondent's determination that the entire net income from the Camfield Manufacturing Company was taxable to petitioner. Petitioner contends that the business was a limited partnership of himself and his wife, and that only 51 per cent of the income...
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