Memorandum Findings of Fact and Opinion
The respondent has determined deficiencies in income tax of William Otto and Emmy Rienacker, husband and wife, for the taxable year ended December 31, 1945, in the amounts of $3,215.61 and $1,423.70, respectively. William Otto Rienacker will hereinafter be referred to as petitioner. The cases were consolidated for trial.
There are two questions presented: (a) Were petitioners...
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