TUTTLE, Circuit Judge.
This petition for review attacks the holding of the Tax Court that appellant, A. L. Powell, was personally taxable with the 1944-1947 income which he claimed was the income of a family partnership consisting of himself and his wife.
The sole issue before this Court is whether a finding by the Tax Court that "there was no intention on the part of the petitioner and his wife, in good faith, to carry on the business of the Powell Company...
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