Memorandum Findings of Fact and Opinion
HILL, Judge:
Respondent determined deficiencies in petitioner's income tax liability for 1940 and 1941 in the respective amounts of $1,521.62 and $1,935.58.
The question is whether the income from certain real estate held in petitioner's name is taxable to him entirely or whether only half such income is taxable to him and the other half to his wife.
Petitioner filed his returns for the years in question...
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