GARDNER, Chief Judge.
This matter is before us on petition to review a decision of the Tax Court which held petitioner liable for a deficiency in income taxes for the taxable year 1941. The basic facts are not in dispute; neither is there any dispute as to the amount of the tax deficiency if such deficiency is to be determined against petitioner.
From 1933 to 1941, petitioner Otto A. Kohl was the sole owner of Bupane Gas Company, an unincorporated enterprise...
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