The Commissioner determined a deficiency in income tax for the taxable year 1945 in the amount of $1,129.52 and a penalty thereon in the amount of $169.43, and an income tax liability for the taxable year 1946 in the amount of $5,796.09. The basic questions presented to us for solution are:
(1) Did respondent err in determining that the Cobb Canvas Co. was not a bona fide partnership between petitioner and his wife, Ida E. Cobb, during the period December 1 through...
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