Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding involves a deficiency in income tax for the calendar year 1943 in the amount of $16,918.84. This deficiency is based on adjustments made by the respondent for both the years 1942 and 1943 and includes the unforgiven portion of the 1942 assessment.
The sole contested issue is whether a bona fide partnership for income tax purposes existed between petitioner, Lee Johns, and his wife...
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