Singletary v. Commissioner of Internal Revenue

WALLER, Circuit Judge.

The subject matter of this case is the income tax consequences of a family partnership which, in 1940, was composed of the husband and wife, and, in 1941, was enlarged to include also the father and mother of the husband.

Lewis Hall Singletary, the taxpayer, and his wife, Mildred, married in 1929, before and after which time she worked as a teacher and as a secretary while he ran a filling station. From their joint earnings they acquired a home, and from their joint savings account of $300 or $400 and a loan of $1000 secured by indorsement of the taxpayer’s father, the…