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SUPORNICK v. COMMISSIONER OF INTERNAL REVENUE

No. 12973.

150 F.2d 110 (1945)

SUPORNICK v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

June 25, 1945.

Attorney(s) appearing for the Case

Samuel Lipschultz, of St. Paul, Minn. (William M. Serbine, Melvin L. Lipschultz, and Sydney W. Goffstein, all of St. Paul, Minn., on the brief), for petitioner.

Harold C. Wilkenfeld, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, and Louise Foster, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before SANBORN, WOODROUGH, and THOMAS, Circuit Judges.

THOMAS, Circuit Judge.

This case is presented on the petition of Joseph Supornick, a taxpayer, to review a decision of the Tax Court of the United States redetermining deficiencies in petitioner's income taxes for the years 1940 and 1941. The controversy is whether during the taxable years involved a partnership existed between the petitioner and his two sons, Meyer and David Supornick. The petitioner and his sons, claiming that a partnership existed, filed their...

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