Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $5,068.60 in the income tax of the petitioner for the calendar year 1941. The petitioner, a nonresident alien, contends that he was not engaged in business in the United States during 1941 as an individual but only as a member of a partnership, and the amount which he received in that year was not income from sources within the United States. He makes other contentions which need...
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