Respondent has determined a deficiency in income tax for the calendar year 1940 in the amount of $2,114.34. Some of respondent's additions to income are not contested. The only question is whether all of the income of a business is taxable to petitioner. Petitioner contends that one-half of the income is taxable to his wife.
Petitioner resides in Columbus, Ohio, and filed his return for the taxable year with the collector for the eleventh district of Ohio.
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