TERES v. COMMISSIONER

Docket No. 36342.

11 T.C.M. 1008 (1952)

William Teres v. Commissioner.

United States Tax Court.

Entered October 21, 1952.


Attorney(s) appearing for the Case

George R. Sherriff, Esq., 42 Broadway, New York, N. Y., and Joseph C. Woodle, Esq., for the petitioner. Robert Margolis, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner has determined a deficiency in petitioner's income tax for the year 1945 of $16,972.72. The deficiency is due to the addition to the income reported on petitioner's return of "(a) Income from partnership — $23,724.82." This adjustment is explained in the deficiency notice as follows:

"(a) It is held that your son, Howard F. Teres, is not a bona fide partner for Federal income tax purposes,...

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