Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income tax for the taxable years 1959 and 1960 in the amounts of $6,677.42 and $4,313.64, respectively.
The issue for decision is whether Wade H. Ballard II was the owner of a partnership interest during the years in question so that the distributable share of partnership net income is taxable to him for those years.
Other issues raised...
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