Woosley v. Commissioner of Internal Revenue

MARTIN, Circuit Judge.

The Tax Court found that, during the three-year period for which income tax deficiencies were assessed and prior thereto, the petitioner, W. B. Woosley, and his wife have been partners in conducting the business and earning the income of Woosley Knitting Mills within the meaning of applicable revenue laws, but, taxwise, not to the extent claimed by the petitioner. Although a part of the capital contributed by the wife to the partnership originated with her and although she contributed managerial and vital additional services, the Tax Court held that the major portion of…