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SEIDEL v. COMMISSIONER

Docket No. 13282.

10 T.C. 1135 (1948)

WALTER F. SEIDEL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 21, 1948.

Attorney(s) appearing for the Case

Allin H. Pierce, Esq., for the petitioner.

Charles D. Leist, Esq., for the respondent.

The Commissioner determined a deficiency of $62,694.04 in the petitioner's income tax for the fiscal year ended January 31, 1944. The previous fiscal year must be considered because of the tax forgiveness provision.

The sole issue is whether the Commissioner erred in holding that the entire net income of Ad. Seidel & Son was taxable to the petitioner instead of to him and his wife in accordance with their partnership...

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