Memorandum Findings of Fact and Opinion
LEECH, Judge:
Respondent has determined a deficiency in income and victory tax for the calendar year 1943 in the sum of $16,182.71. This deficiency arises through the inclusion in petitioner's income of the total gain derived from the operation of a business known as the Winchester Hotel, one-half of the income from this business having been reported by petitioner's wife as partnership income realized by her. The only...
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