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SIMONS v. COMMISSIONER

Docket Nos. 6212, 6213.

7 T.C. 114 (1946)

LEONARD N. SIMONS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. LAWRENCE J. MICHELSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 12, 1946.

Attorney(s) appearing for the Case

R. M. O'Hara, Esq., and Harry A. Smith, Esq., for the petitioners.

A. J. Friedman, Esq., for the respondent.

The respondent determined deficiencies of $2,966.81 and $3,053.12 in the income tax of the petitioners, Leonard N. Simons and Lawrence J. Michelson, respectively, for the year 1941.

The sole issue is whether or not a partnership composed of the petitioners and their wives was valid and recognizable for Federal tax purposes.

FINDINGS OF FACT.

The petitioners are individuals residing and having their place of...

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