Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined a deficiency in petitioners' income tax for the year 1957 in the amount of $1,722.99.
Petitioner Alfred G. Moitozo held a 32 percent interest in a partnership. The issue is whether in the year 1957 he held this interest 6½ months or 11 months, or, as related to his income, whether he was required to report 6½ twelfths or 11 twelfths of 32 percent of the partnership...
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