TINLING v. COMMISSIONER

Docket No. 8996.

7 T.C. 1393 (1946)

HUGH B. TINLING, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 26, 1946.


Attorney(s) appearing for the Case

W. W. Witherspoon, Esq., for the petitioner.

Douglas Barnes, Esq., for the respondent.


This case involves an income tax deficiency for 1943 in the amount of $13,034.77. The year 1942 is involved to the extent of the unforgiven portion of the tax liability for that year pursuant to the Current Tax Payment Act of 1943. Petitioner claims an overpayment of $2,686.14.

Petitioner was a member of a partnership during 1942 and 1943, and the question for decision is the proper allocation of his partnership income between separate and community income.

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