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WOODARD v. COMMISSIONER

Docket Nos. 22203, 22204.

9 T.C.M. 1187 (1950)

W. R. Woodard v. Commissioner. Blanche Clarke Woodard v. Commissioner.

United States Tax Court.

Entered December 29, 1950.

Attorney(s) appearing for the Case

Dana Latham, Esq., 1112 Title Guarantee Bldg., 411 W. 5th St., Los Angeles, Calif., for the petitioners. R. E. Maiden, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies in income tax of $5,561.22 and $5,564.22 against the petitioners for 1944. The only issue for decision is whether the Commissioner erred in holding that the two younger sons of the petitioners were not limited partners and that the portion of the income which was theirs under the partnership agreement was taxable instead to the petitioners.

Findings of Fact

The petitioners...

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