Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding involves a deficiency in income tax for the year 1944 in the amount of $1,603.52. The sole issue is whether all the net income of a business conducted under the name of "Albert C. Phy" during the taxable year 1944 is taxable to petitioner as sole proprietor.
Findings of Fact
Petitioner, Albert C. Phy, is the husband of Emily S. Phy. They were married in August 1921 and...
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