Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income tax of $141.16 for 1946 against Walburga Oesterreich and deficiencies against Wilshire Holding Corporation of $1,584 in declared value excess profits tax, $3,097.83 in excess profits tax and $1,834.06 in income tax, for 1945, and $2,798.20 in income tax for 1946. The only issue for decision is whether payments made by Wilshire Holding Corporation to Walburga Oesterreich for...
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