The Commissioner determined a deficiency of $2,739.14 in income tax of the petitioner for the year 1944. The only issue is whether one-half or only one-fourth of the income of Odle Chevrolet Co. for 1944 is taxable to the petitioner. The decision depends upon whether his wife Ruth is recognized as a partner.
FINDINGS OF FACT.
The petitioner filed a separate individual income tax return for 1944 with the collector of internal revenue for the district of Tennessee...
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