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HIMES v. COMMISSIONER

Docket Nos. 16608, 16609.

8 T.C.M. 515 (1949)

William D. Himes v. Commissioner.

United States Tax Court.

Entered May 23, 1949.

Attorney(s) appearing for the Case

Andrew B. Young, Esq., and David P. Brown, Jr., Esq., both of Philadelphia, Pa., for the petitioner. Karl W. Windhorst, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

In Docket No. 16609 the respondent determined deficiencies of $19,234.71 and $59,301.46 in the petitioner's income tax liability for the years 1941 and 1943, respectively. In Docket No. 16608 he determined a deficiency of $15,046.30 in the petitioner's income tax liability for the year 1944.

The issues are:

1. Is petitioner taxable on 3/17ths of the income of a partnership representing the

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