COLE v. COMMISSIONER OF INTERNAL REVENUE

No. 10813.

173 F.2d 893 (1949)

COLE v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Sixth Circuit.

April 21, 1949.


Attorney(s) appearing for the Case

Scott P. Crampton, of Washington, D. C. (Geo. E. H. Goodner and Scott P. Crampton, both of Washington, D. C., on the brief), for petitioner.

Irving I. Axelrad, of Washington, D. C. (Theron L. Caudle, Ellis N. Slack and Irving I. Axelrad, all of Washington, D. C., on the brief), for respondent.

Before SIMONS, MARTIN and McALLISTER, Circuit Judges.


PER CURIAM.

The petitioning taxpayer seeks review of the decision of the Tax Court of the United States holding that there are deficiencies in his income tax for the years 1943, 1944, and 1945, in the respective amounts of $28,202.18, $37,358.18, and $32,082.28. The issue presented is whether income attributed to the taxpayer's wife, by virtue of a husband and wife partnership which included an additional partner, is taxable to the husband.

The taxpayer conveyed...

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