ESTATE OF HANNAMAN v. COMMISSIONER

Docket No. 14194.

15 T.C. 327 (1950)

ESTATE OF GEORGE L. HANNAMAN, DECEASED, HARRIETT HANNAMAN, ADMINISTRATRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 28, 1950.


Attorney(s) appearing for the Case

J. Everett Blum, Esq., for the petitioner.

Wilford H. Payne, Esq., and William E. Koken, Esq., for the respondent.


This proceeding involves a deficiency in income tax for the period January 1, 1943, to November 10, 1943, in the amount of $44,531.77. The tax liability of the decedent for 1942 is involved due to the foregiveness feature of the Current Tax Payment Act of 1943.

The sole question is whether the respondent erred in his determination that decedent's wife was not a bona fide partner for Federal tax purposes in two separate partnerships and that the profits distributable...

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