PER CURIAM.
It appearing that the taxpayer was adjudicated liable for 60% of the income earned by a family partnership, to the capital of which he had contributed by a loan to his wife and a gift to the trustee of his minor daughter, that the partnership was in a real sense a continuation of a corporate business in which the taxpayer had the controlling interest, and that the successful operation of the partnership business was due in large measure to the goodwill...
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