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RHINE v. COMMISSIONER

Docket No. 18786.

9 T.C.M. 1078 (1950)

Earl Rhine v. Commissioner.

United States Tax Court.

Entered November 28, 1950.

Attorney(s) appearing for the Case

Peter L. Wentz, Esq., for the petitioner. Frank M. Cavanaugh, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $61,116.36 in petitioner's income tax for the year 1944. The issue which we have to decide is whether the Commissioner erred in refusing to recognize petitioner's wife and daughter as members of a partnership with petitioner and in treating petitioner as a sole proprietor.

Findings of Fact

Petitioner is an individual...

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