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KENT v. COMMISSIONER OF INTERNAL REVENUE

No. 10617.

170 F.2d 131 (1948)

KENT v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Sixth Circuit.

September 27, 1948.

Attorney(s) appearing for the Case

Lewis R. Donelson, III, of Memphis, Tenn. (Lewis R. Donelson, III and Allan Davis, both of Memphis, Tenn., on the brief), for appellant.

Louise Foster, of Washington, D. C. (Theron L. Caudle, Charles Oliphant, Sewall Key, Rollin H. Transue, A. F. Prescott and Louise Foster, all of Washington, D. C., on the brief), for appellee.

Before SIMONS, McALLISTER, and MILLER, Circuit Judges.

McALLISTER, Circuit Judge.

Petitioner sought redetermination of deficiencies in income taxes, which were asserted by the Commissioner for 1940 and 1941. The result of respondent's action was to tax petitioner on certain income arising out of three different partnerships: (1) Southern Air Services; (2) the Pine Bluff School of Aviation; and (3) Helena Aero Tech School. Petitioner claims that his wife was the owner of the interests in the partnerships which were taxed...

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