Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioner seeks a redetermination of deficiencies in income tax for 1940 and 1941 in the amounts of $9,201.72 and $9,840.54, respectively.
Petitioner charges respondent erred in refusing to recognize a partnership between petitioner's wife and another, and in attributing to petitioner his wife's distributive share of the income thereof.
The parties have filed a stipulation...
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