MURRAH, Circuit Judge.
The question presented by this appeal is whether the petitioner and his wife were business partners for income tax purposes in the taxable years 1943 and 1944. Finding as a fact that the petitioner and his wife did not intend to join together as partners in the conduct of the business known as Ray Jackson and Sons, the Tax Court sustained the determination of the Commissioner, assessing a deficiency against the petitioner. It is the contention...
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