EWING v. COMMISSIONER

Docket No. 4405.

5 T.C. 1020 (1945)

FRED W. EWING, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 31, 1945.


Attorney(s) appearing for the Case

Walter H. Scott, Esq., for the petitioner.

Cecil H. Haas, Esq., for the respondent.


This proceeding involves a deficiency of $12,611.31 in petitioner's income tax for 1940. The questions in issue are (1) whether a valid business partnership for income tax purposes existed between petitioner and his wife in 1940 with respect to the purchase and sale and rental of road building and construction equipment; and (2) whether petitioner is entitled to a long term capital loss deduction on account of the worthlessness of stock of the Clifton Building Co., a corporation...

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