The respondent has determined income tax deficiencies of $5,464.45 for 1940 and $9,693.84 for 1941. The only question in issue is whether there was a partnership between petitioner and his wife, the wife acting as trustee for their two daughters.
FINDINGS OF FACT.
Petitioner is a resident of Jacksonville, Florida. He filed his income tax returns for 1940 and 1941 with the collector of internal revenue for the district of Florida, at Jacksonville.
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