ATKINS, Judge:
The respondent determined deficiencies in income tax for the calendar years 1952 and 1953 in the respective amounts of $6,600.10 and $34,541.46. The basic issue is whether the business conducted in the name of Astell Refractories Company was conducted by the petitioner Harry L. Bialock as a sole proprietorship or whether it was conducted by him and his two minor children as a partnership, the decision of which will determine whether the petitioner...
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