Memorandum Findings of Fact and Opinion
This case involves deficiencies in petitioner's income tax determined by the Commissioner of Internal Revenue for the calendar years 1943, 1944 and 1945, in the respective amounts of $28,754.24, $38,462.18 and $33,166.10. The deficiency asserted in each of these years arises out of the refusal of the Commissioner to recognize Monica M. Cole, the wife of the petitioner, as a member of the partnership of Cole & Company,...
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