Memorandum Findings of Fact and Opinion
The parties to these proceedings have stipulated that the only issues for decision are (1) should $30,000 accounts payable be included in the liabilities of the partnership of Sam and Morris Koscove as of December 31, 1940, and (2) are petitioners liable for fraud for any of the years 1941, 1942, 1945 and 1946.
The income tax deficiencies
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