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ELLIS v. COMMISSIONER

Docket No. 26888.

10 T.C.M. 234 (1951)

Jess J. Ellis v. Commissioner.

United States Tax Court.

Entered March 13, 1951.

Attorney(s) appearing for the Case

Edward R. Moran, Esq., 807 Ohio Bldg., Toledo, Ohio, for the petitioner. Cyrus A. Neuman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined deficiencies in income tax of $6,883.53 and $27,565.92 in the calendar years 1946 and 1947, respectively. The issue for decision is whether the Commissioner erred in adding to petitioner's income in each year the entire income of an "alleged" partnership between petitioner and his son.

Findings of Fact

The petitioner is an individual. He filed his income...

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