Memorandum Findings of Fact and Opinion
VAN FOSSAN, Judge:
These proceedings involve deficiencies in income tax for 1947 in the amount of $16,794.01 in Docket No. 54316 and $5,045.46 in Docket No. 54317. Increased deficiencies were claimed by the respondent at the hearing. The issues are: (1) Whether the net profits of Marine Industries, a partnership in which petitioner Harold G. Williams had an interest, are taxable as ordinary income or long-term capital...
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