POPE, Circuit Judge.
The Tax Court upheld the Commissioner's determination of a deficiency in petitioner's income taxes for the calendar years 1946-1947. Prior to 1946, Miller Paint Co., was a partnership, composed of three brothers, who, as sole owners of the partnership business, had inherited it from their father. The partnership operated a store business selling paint and related products at retail and wholesale and did some manufacturing of paint. The partnership...
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