SYMES, District Judge.
This matter is before the court on motion to dismiss filed by the defendant Ralph Nicholas, Collector of Internal Revenue for the District of Colorado. The undisputed facts of the case are as follows:
For some years prior to January 1, 1944, Jacques Adler, individually, was engaged in a general jewelry business. On January 1, 1944, Jacques Adler and May E. Adler formed a general partnership to engage in the jewelry business, which partnership...
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