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SIMONSON v. COMMISSIONER

Docket No. 8148.

5 T.C.M. 718 (1946)

Archibald V. Simonson v. Commissioner.

United States Tax Court.

Entered August 14, 1946.

Attorney(s) appearing for the Case

Charles J. Costabell, Esq., 61 Broadway, New York 6, N. Y., for the petitioner. Walt Mandry, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARLAN, Judge:

The respondent determined a deficiency in the income tax of petitioner for the calendar year 1941 in the amount of $44,375.23. The issues are:

1. Is the petitioner taxable upon his wife's distributive share of the net income of an alleged partnership?

2. Is the petitioner entitled to a deduction for the cost of certain films used in the...

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