MULLINS, Chief Judge.
For the years 1943, 1944 and 1945, the Commissioner made deficiency assessments for income taxes against the plaintiff Grayson for some $247,000, which he paid. Plaintiff now sues to recover back some $100,000, or less than half of the deficiency, on the ground that the Commissioner wrongfully refused to recognize, for income tax purposes, the plaintiff's alleged family partnership.
The evidence shows that the taxpayer has since the year...
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