The Commissioner determined deficiencies in petitioner's income tax for the years 1940 and 1941 in the respective amounts of $2,879.86 and $13,737.43. The only adjustment in issue is the inclusion in gross income of all the net income from a business conducted under the name of Sing Oil Co.
In the petition it is alleged that there was a bona fide partnership between petitioner and his wife during the year 1940 and that they correctly divided the income, 50 percent...
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