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JENNINGS v. COMMISSIONER

Docket No. 11972.

10 T.C. 505 (1948)

DAVID L. JENNINGS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 23, 1948.

Attorney(s) appearing for the Case

Milton J. Sabath, Esq., for the petitioner.

Maurice S. Bush, Esq., for the respondent.

Respondent determined a deficiency in petitioner's 1943 income tax in the amount of $4,139.13. The deficiency, based in part on adjustments to 1942 income, was computed under the forgiveness features of the Current Tax Payment Act of 1943. Because certain minor adjustments by respondent are not in issue, the sole remaining question is whether a family partnership consisting of petitioner, his wife, and his son, is valid for Federal tax purposes.

FINDINGS OF FACT...

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