Ed Krist and Florine Krist v. Commissioner of Internal Revenue

LING, District Judge.

Petitioners seek review of a decision of The Tax Court.

The following facts are stipulated: Petitioner and Florine Krist were husband and wife during the taxable year in question, residing in Los Angeles, California. They filed separate returns for the calendar year 1944 with the collector of internal revenue for the sixth district of California, at Los Angeles.

On or about October 1,1939, petitioner and one Morris Greenspun formed a partnership known as Ed Krist Company (hereinafter referred to as the partnership). The purpose of the partnership was to purchase and…