Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioners challenge respondent's determination of a deficiency of $3,685.81 in income tax for 1945, as well as a penalty of $393.26 asserted under Internal Revenue Code, section 294 (d) (2).
The issue presented is whether Internal Revenue Code, section 107, is applicable to petitioner's share of a fee received in the taxable year for legal services rendered by petitioner John...
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