Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax of $16,094.41 for the calendar year ended December 31, 1944, viz., $10,496.02, which the Commissioner originally determined, and an additional $5,598.39, which the respondent claimed in his amended answer to the petition.
The sole issue is whether the income realized by petitioner incident to his withdrawal from a law partnership in 1944 is taxable at capital...
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