FORSYTHE v. COMMISSIONER

Docket No. 10920.

10 T.C. 417 (1948)

SINNE B. FORSYTHE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 11, 1948.


Attorney(s) appearing for the Case

Clarke W. McCants, Esq., and Clint T. Graydon, Esq., for the petitioner.

Edward L. Potter, Esq., for the respondent.


The Commissioner determined a deficiency of $85,854.30 in petitioner's income and victory tax for 1943 by adding to income reported one-half of the profits of a dairy business, operated by himself and wife under a partnership agreement, which half he contends was income of the wife and taxable to her.

FINDINGS OF FACT.

Petitioner, a resident of Columbia, South Carolina, filed a separate income tax return for 1943 with the collector of internal revenue for...

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