Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income tax for the calendar years 1944 and 1945 in the respective amounts of $19,644.73 and $15,567.56. The sole contested issue is whether petitioner and his wife were carrying on business as partners during the taxable years 1944 and 1945, recognizable as such for tax purposes.
Findings of Fact
Petitioner, a resident of Orlando, Florida, since 1926, filed his tax returns...
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