Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $20,050.83 against the petitioner as transferee of Harry E. LeFils, deceased taxpayer, for income taxes for 1946. The only issue presented here is whether the deficiency should be credited with $12,459.58, the amount of an overassessment due to Ethel Hoyt LeFils Hemenway for over-payment of her income tax in 1946 when she was the taxpayer's wife.
Findings of Fact
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