DUFFY, Chief Judge.
The Starr Pen Company was a partnership organized in 1935 by members of the Starr family. During 1943 and 1944 Joseph Starr, hereinafter called taxpayer, had a 70 per cent interest in the partnership, and Samuel Starr and Jack Starr each had a 15 per cent interest therein. The distributive income of the partnership was its net income after allowances
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