Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined a deficiency against petitioners, who are husband and wife filing a joint return, of $405.64 in income tax for the year 1949, all of which is in controversy. The sole question is whether the disallowance of a "business loss" on the ground that the business belonged not to petitioners but to their daughter was proper.
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