Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income and victory tax for the calendar year 1943 in the amount of $11,774.32. The single issue involved is whether the petitioner's income for 1943 may properly be increased by such amounts as represent partnership income distributed to five of his children in that year. The partnership interests of the children were originally acquired by virtue of a $4,000 gift made to each of them...
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