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SCHULMAN v. COMMISSIONER

Docket No. 38940.

12 T.C.M. 448 (1953)

Edna Schulman v. Commissioner.

United States Tax Court.

Entered April 24, 1953.

Attorney(s) appearing for the Case

Marvin K. Collie, Esq., 11th Floor, Esperson Building, Houston, Tex., and R. P. Bushman, Esq., for the petitioner. George H. Seefeld, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

The respondent has determined deficiencies in income tax as follows:

  Year                  Deficiency

  1946................  $12,246.10
  1947................   10,151.53

The first issue to be decided is whether petitioner, her son, Alfred Schulman, and the Billy Schulman trust were bona fide partners in the partnership...

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