Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in the income tax of petitioner for the years and in the amounts as follows:
Year Deficiency 1952........... $ 91.97 1953........... 1,207.85 1954........... 2,015.31
The sole issue is whether petitioner is taxable on a fifty percent share of the distributable income of a partnership for the taxable years 1952,...
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