GUGENHEIM v. COMMISSIONER

Docket Nos. 45684, 45685.

17 T.C.M. 203 (1958)

T.C. Memo. 1958-41

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

United States Tax Court.

Filed March 17, 1958.


Attorney(s) appearing for the Case

Wentworth T. Durant, Esq., for the petitioners. Roy E. Graham, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

These cases are before us upon remand from the Court of Appeals for the Fifth Circuit, 239 Fed. (2d) 286, (December 14, 1956) [57-1 USTC ¶ 9248].

The respondent determined a deficiency of $3,721.41 for the calendar year 1947 against each of the petitioners. The petitioners contest the determinations (1) that their daughter was not a member of a family partnership during the firm's fiscal...

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