ROSSIO v. COMMISSIONER

Docket No. 11547.

6 T.C.M. 1240 (1947)

Albert Rossio v. Commissioner.

United States Tax Court.

Entered November 26, 1947.


Attorney(s) appearing for the Case

Vincent M. DeMelto, Esq., 1200 Marshall Bldg., Cleveland, Ohio, for the petitioner. Howard M. Kohn, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies in income tax of $4,539.35 for 1941 and in income and Victory taxes of $12,982.53 for 1943. The only question to be determined is whether the business of Rossio Jewelry Company was a partnership composed of petitioner and his wife for income tax purposes.

Findings of Fact

The following facts were stipulated:

The petitioner is a resident of Cleveland, Ohio,...

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