JACKSON v. COMMISSIONER

Docket No. 21207.

19 T.C. 133 (1952)

HUGH C. JACKSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 6, 1952.


Attorney(s) appearing for the Case

Bayley Kohlmeier, Esq., and George H. Koster, Esq., for the petitioner.

T. M. Mather, Esq., for the respondent.


The Commissioner has determined deficiencies in income tax for 1943 and 1944 in the amounts of $9,342.01 and $5,371.41, respectively. The only issue for decision is whether the Commissioner erred in determining that the petitioner's wife, Ada Jackson, could not be recognized as a partner for tax purposes, and that partnership income credited to her is taxable to the petitioner.

FINDINGS OF FACT.

The petitioner and his wife, Ada Jackson, resided in Syracuse...

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