BENSON v. COMMISSIONER

Docket No. 6257.

6 T.C. 748 (1946)

LEWIS COLEMAN BENSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 17, 1946.


Attorney(s) appearing for the Case

Robert R. Milam, Esq., for the petitioner.

F. L. Van Haaften, Esq., for the respondent.


The respondent has determined income tax deficiencies of $5,464.45 for 1940 and $9,693.84 for 1941. The only question in issue is whether there was a partnership between petitioner and his wife, the wife acting as trustee for their two daughters.

FINDINGS OF FACT.

Petitioner is a resident of Jacksonville, Florida. He filed his income tax returns for 1940 and 1941 with the collector of internal revenue for the district of Florida, at Jacksonville.

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