KERNER, Circuit Judge.
This is a petition to review a decision of the Tax Court which determined that no partnership existed between petitioner and his wife for income tax purposes during the year 1943.
On July 1, 1943, petitioner and his wife executed a partnership agreement which recited that they were the equal owners of the tangible assets of a trunk company, and that they agreed to engage in the trunk and case business under the name of Wellington Trunk...
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