Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in income tax for the years 1940 and 1941 against Irene McCullough in the respective amounts of $362.69 and $3,446.10, and against R. Verne McCullough in the respective amounts of $467.14 and $3,242.70. Certain adjustments made by the respondent are not contested. The sole issue now in controversy is whether each petitioner is properly taxable with 50 per cent of the net income of a partnership...
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