Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
Respondent determined deficiencies in income tax for the year 1946 against petitioner Esther Gladys Gugenheim in the amount of $1,276.17 and against petitioner Albert Dick Gugenheim in the amount of $1,276.18.
The sole issue is whether petitioners' daughter, Betty Ann Gugenheim Manheim, was a partner with petitioner Albert Dick
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