Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in income tax for 1947 of $7,662.27 against Kaufman and $7,208.55 against Bedrick. The only issue for decision is whether the principal amount of 23 notes received by each petitioner in May 1947, but payable after 1947, represented income taxable to the petitioners in 1947.
Findings of Fact
The petitioners filed individual returns for 1947 with the collector of internal...
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