GUGENHEIM v. COMMISSIONER

Docket Nos. 45684, 45685.

13 T.C.M. 1000 (1954)

T. C. Memo. 1954-183

Albert Dick Gugenheim v. Commissioner. Esther Gladys Gugenheim v. Commissioner.

United States Tax Court.

Filed October 22, 1954.


Attorney(s) appearing for the Case

Wentworth T. Durant, Esq., for the petitioners. Frank C. Allen, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The respondent determined a deficiency in income tax for 1947 in the amount of $3,721.41 against each of the petitioners. The whole amount of the deficiencies is not in controversy since the petitioners have agreed to assessment of a part thereof. Two issues are presented: (1) Whether a portion of the income of a partnership, A. D. Gugenheim Company, during its fiscal year ended June 30, 1947, is taxable...

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