Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in petitioner's income taxes for the calendar years 1937 and 1938 in the respective amounts of $3,529.38 and $2,257.81, upon the theory, challenged by petitioner in this proceeding, that petitioner is taxable upon the net income of the Estate of Charles H. Bosworth pursuant to the provisions of sections 162(b) and 22(a) of the Internal Revenue Code.
The facts, as stipulated...
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