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BOYLIN v. COMMISSIONER

Docket No. 21039.

14 T.C. 542 (1950)

FRANK BOYLIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 4, 1950.

Attorney(s) appearing for the Case

Paul N. Wiener, Esq., for the petitioner.

Sheldon V. Ekman, Esq., for the respondent.

The Commissioner determined a deficiency of $22,195.05 in the income tax of the petitioner for 1944. The only issue is whether the Commissioner erred in taxing as a part of the petitioner's income the 15 per cent of partnership income which was to go to his wife under an agreement entered into in March, 1944.

FINDINGS OF FACT.

The petitioner filed his individual income tax return for 1944 with the collector of internal...

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