CHASE, Circuit Judge.
In his income tax return for the calendar years 1944 and 1945, the petitioner reported as part of his gross income only a portion of the net income of a business known as the Bernard Company. He did so on the ground that his interest in the business was only that of a partner with his wife, a daughter and a son, Richard. The Commissioner determined a deficiency for each year by including the entire net profit of the business in the gross income...
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