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JAPP v. COMMISSIONER

Docket No. 20264.

9 T.C.M. 705 (1950)

Leonard M. Japp and Eugenia Japp v. Commissioner.

United States Tax Court.

Entered August 17, 1950.

Attorney(s) appearing for the Case

Herbert Portes, Esq., 59 E. Van Buren St., Chicago 5, Ill., and Leonard Schanfield, Esq., for the petitioners. Charles D. Leist, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

This proceeding involves a deficiency in income tax for 1944 in the amount of $159,017.47. Of the several issues raised by the pleadings, all except two have been settled by stipulation of the parties. The two remaining issues are whether respondent erred in his refusal to recognize the validity, for federal income tax purposes, of an alleged partnership between the petitioners Leonard...

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