The Commissioner determined a deficiency in income tax for the taxable year ended December 31, 1943, in the amount of $63,256.74. The basic issue involved herein is whether or not there existed a partnership, to be recognized for computing income tax, consisting of the petitioner, his son Harold, and his wife Marion, during the taxable year 1943. In his brief petitioner states that he does not question the respondent's failure to recognize the petitioner's wife as a partner...
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