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NIELSON v. COMMISSIONER

Docket Nos. 21103, 21104.

9 T.C.M. 57 (1950)

Sigvald Nielson v. Commissioner. Madge Nielson v. Commissioner.

United States Tax Court.

Entered January 26, 1950.

Attorney(s) appearing for the Case

Harry R. Horrow, Esq., for the petitioners. Earl C. Crouter, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner has determined a deficiency in income tax for the year 1944 in the amount of $405.74, in Docket No. 21103; and of $450.45, in Docket No. 21104. These proceedings have been consolidated for trial and opinion.

The only issue is whether the petitioner, Sigvald Nielson, as a member of a law partnership, is entitled to apply section 107, Internal Revenue Code, so as to include in...

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