Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $1,489.14 in the income tax of the petitioner for 1946. The two issues for decision are whether $8,600.74, representing uncollected commissions of a salesman of a partnership in which the petitioner had a one-half interest, was income of the partnership for 1946, and whether the partnership was entitled to a deduction of $7,000 for 1946 paid in settlement of a suit brought against...
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