Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
The Commissioner determined a deficiency of $24,427.86 in petitioner's income and victory tax for 1943, in part by including in income 25 percent of the profits of an undertaking business for the period April 1-December 31, 1943, which profits were credited to his sister pursuant to a partnership agreement between them dated April 1, 1943. Petitioner contends that his sister rendered vital services...
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