United States Tax Court.
Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in income tax and additions to the tax for negligence as follows:
Year Deficiency Penalty 1938 .............. $1,047.05 $52.35 1939 .............. 837.32 41.87 1940 .............. 4,223.63 211.18
The issues for decision are:
For 1938 —
(a) Whether the petitioner, as a joint venturer...
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