LINDLEY, Circuit Judge.
The Commissioner of Internal Revenue assessed against petitioner taxpayer deficiencies and penalties in the sum of $82,352.85, in income taxes for the years 1942 to 1947 inclusive, because of unreported income for those years. Upon appeal, the Tax Court entered a judgment approving the assessment, which petitioner now seeks to set aside. The decisive question before us is whether the taxpayer and his wife were partners or engaged in a joint...
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