Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in the petitioner's income tax for 1943, 1944 and 1945 in the amounts of $42,627.63, $24,850.42 and $78,383.16. The year 1942 is also involved by reason of the forgiveness feature of the Current Tax Payment Act of 1943.
The only issue for decision is whether the Commissioner erred in determining that the petitioner's brothers, Isaiah C., William H., Warren H., and Dale L. Mumford...
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