Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined deficiencies in income tax for 1944 and 1945, in the respective amounts of $10,754.33 and $13,729.11.
The sole issue presented is whether, in the years in question, petitioner and his son were partners in a valid and subsisting partnership in a business conducted under the name of U. S. Typewriter Ribbon Mfg. Co., and thus whether respondent erred in taxing to petitioner...
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