The respondent determined that there was a deficiency of $449.85 in the income tax of petitioner for the calendar year 1948. He further determined that petitioner was liable for a 5 per cent addition to tax under section 293 (a) of the Internal Revenue Code.
The principal issue concerns the proper method of treatment of personal earnings of petitioner, when by agreement such earnings were to be contributed to a partnership in which he had a 40 per cent interest and...
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