Memorandum Findings of Fact and Opinion
SMITH, Judge:
This proceeding is for the redetermination of deficiencies in income tax for 1938 and 1940 of $325.93 and $880.59, respectively. The questions in issue are:
(1) Whether certain interest and capital gains received by the petitioner's wife, Mary Homchis, in the years 1938 and 1940 are taxable to the petitioner.
(2) Whether for the year 1940 petitioner is entitled to deduct depreciation upon...
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