Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in the petitioners' income tax for the calendar years 1939, 1940, and 1941, in the respective amounts of $1,206.94, $1,222.10, and $2,180.56, and in declared value excess-profits tax for 1941, in the amount of $93.42.
The single question at issue is whether petitioners are an association taxable as a corporation under section 3797 (a) (3) of the Internal Revenue Code.
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