MacPherson v. Commissioner

*654OPINION.

Lansdon:

The single issue here is whether the amounts which the respondent added to the income of the petitioner in the taxable years in the circumstances set forth are taxable to him. In support of his action the respondent denies (1) that the purported partnership agreement was valid under the laws of Massachusetts, (2) that petitioner’s wife ever acquired any interest in the Cambridge Eubber Co., and (3) that any portion' of the income from such business in 1922 and 1923 was separate income of the petitioner’s wife in the taxable years.

Since we are concerned only with the income of…