This proceeding involves a deficiency of $12,611.31 in petitioner's income tax for 1940. The questions in issue are (1) whether a valid business partnership for income tax purposes existed between petitioner and his wife in 1940 with respect to the purchase and sale and rental of road building and construction equipment; and (2) whether petitioner is entitled to a long term capital loss deduction on account of the worthlessness of stock of the Clifton Building Co., a corporation...
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