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HARVEY v. COMMISSIONER

Docket No. 42478.

21 T.C. 1020 (1954)

FRED M. HARVEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 30, 1954.

Attorney(s) appearing for the Case

Llewellyn A. Luce, Esq., and Albert B. Maloney, C. P. A., for the petitioner.

J. Frost Walker, Esq., and W. Preston White, Jr., Esq., for the respondent.

Respondent determined the following deficiencies in income tax:

Year                                                   Deficiency

1943 ----------------------------------------------   $236,119.04
1945 ----------------------------------------------    127,392.44
1946 ----------------------------------------------    132,618.99

The primary issue presented is whether a partnership existed between petitioner, his wife, and two trusts...

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