Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding arises out of respondent's determination of deficiencies in income tax for 1945. Certain adjustments are not contested. The taxes in controversy are in the amount of $9,721.31 with respect to petitioner Harry S. Davega, and $12,046.59 with respect to petitioner Dorothy R. Davega. The sole issue is whether petitioners, husband and wife, are each taxable on one-half of the income of an enterprise...
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