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HARKNESS v. COMMISSIONER OF INTERNAL REVENUE

Nos. 12618, 12619.

193 F.2d 655 (1951)

HARKNESS v. COMMISSIONER OF INTERNAL REVENUE (two cases).

United States Court of Appeals Ninth Circuit.

Rehearing Denied January 29, 1952.

Attorney(s) appearing for the Case

Philip S. Ehrlich, Albert A. Axelrod, R. J. Hecht, Irving Rovens, San Francisco, Cal., for petitioners.

Ellis N. Slack, Acting Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Harry Marselli, Sp. Assts. to the Atty. Gen., for respondent.

Before MATHEWS, HEALY and POPE, Circuit Judges.

POPE, Circuit Judge.

These cases, consolidated for hearing, present the question whether in the year 1943 there was, for tax purposes, a valid family partnership composed of the two petitioners, who are husband and wife, and their two children. The opinion and findings of the Tax Court, reported in 13 T.C. 1039, recite the facts surrounding the formation of the alleged partnership, the agreement entered into by the parties, and their...

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