Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding involves deficiencies in income tax for the calendar years 1943, 1944 and 1945, in the respective amounts of $7,813.87, $34,670.09, and $79,814.48.
The contested issue is whether, during the taxable periods involved, the Rainbow Art Co. was a bona fide partnership for income tax purposes.
The case was submitted on oral stipulations, oral testimony and exhibits. The stipulated...
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