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SPARKS v. COMMISSIONER

Docket No. 52914.

15 T.C.M. 364 (1956)

T.C. Memo. 1956-71

Harry L. Sparks and Rex Wanda Sparks v. Commissioner.

United States Tax Court.

Filed March 23, 1956.

Attorney(s) appearing for the Case

William P. Rosenthal, Esq., and Leonard Schanfield, Esq., for the petitioners. Robert R. Veach, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined deficiencies in petitioners' income tax liability for the calendar years 1948 and 1949 in the amounts of $17,309.12 and $4,656.42, respectively. The deficiencies resulted from respondent's refusal to recognize a partnership between petitioner Harry L. Sparks and his son Joe C. Sparks, and his consequent inclusion of income reported by Joe C. Sparks in petitioners' income for the years in question.

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