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COLLAMER v. COMMISSIONER OF INTERNAL REVENUE

No. 6144.

185 F.2d 146 (1950)

COLLAMER v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fourth Circuit.

Decided November 8, 1950.

Attorney(s) appearing for the Case

William L. Parker, Norfolk, Va., for petitioner.

Sumner M. Redstone, Sp. Asst. to Atty. Gen. (Theron Lamar Caudle, Asst. Atty. Gen. and Ellis N. Slack, Sp. Asst. to Atty. Gen., on brief), for respondent.

Before PARKER, Chief Judge, and DOBIE, Circuit Judge, and TIMMERMAN, District Judge.

DOBIE, Circuit Judge.

This is an appeal by E. L. Collamer, Sr., (hereinafter called taxpayer) from a decision of the Tax Court of the United States upholding the refusal of the Commissioner of Internal Revenue to recognize the existence of a partnership relation between taxpayer and his wife, in the operation of a moving picture theatre. Accordingly, the total income from the theatre for the calendar years 1943 and 1944 was held to be taxable to the taxpayer, against...

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