Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding was brought for a redetermination of a deficiency of $54,960.10 in petitioner's income tax for 1941.
The primary question turns upon the correctness of respondent's action in attributing to petitioner income asserted by petitioner to be allocable to his wife by reason of a family partnership arrangement.
The parties submitted a stipulation of facts and evidence was adduced...
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