Memorandum Opinion
SMITH, Judge:
The Commissioner has determined deficiencies in petitioner's income tax for 1938 and 1939 in the amounts of $2,043.96 and $1,825.58, respectively. The only question in issue is whether petitioner is taxable on all of the earnings from an oil agency business in which he claims to have assigned a one-half interest to his wife under a partnership agreement.
[The Facts]
Petitioner is a resident of Hinton...
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