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HARKNESS v. COMMISSIONER

Docket Nos. 16407, 16408.

13 T.C. 1039 (1949)

MOLLY A. HARKNESS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. FLOYD J. HARKNESS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 22, 1949.

Attorney(s) appearing for the Case

Philip S. Ehrlich, Esq., R. J. Hecht, Esq., and Le Roy H. Guntner, Esq., for the petitioners.

T. M. Mather, Esq., for the respondent.

The above entitled cases were consolidated for hearing. Respondent determined a deficiency in the income tax liability of petitioner Floyd J. Harkness in the amount of $65,367.27 for the calendar year 1943 and a deficiency in the income tax liability of petitioner Molly A. Harkness in the amount of $64,781.64 for the same year. The only issue raised in this proceeding is whether a valid family partnership existed between petitioners and their children, Floyd J. Harkness,...

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