MARTIN v. COMMISSIONER

Docket No. 5915.

4 T.C.M. 924 (1945)

Charles G. Martin v. Commissioner.

United States Tax Court.

Entered September 28, 1945.


Attorney(s) appearing for the Case

Saul I. Radin, Esq., 67 West 44th St., New York, N. Y., for the petitioner. William Schwerdtfeger, Esq. and Thomas R. Charshee, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

Respondent has determined deficiencies in petitioner's income tax for the calendar years 1940 and 1941 in the respective amounts of $8,031.94 and $242.10. Several issues were raised by the petition herein but on only one was evidence adduced at the hearing. That issue is whether respondent erred in disregarding for tax purposes the existence of a partnership purportedly formed in 1940 by petitioner and his daughter to continue...

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