Hougland v. Commissioner

MARTIN, Circuit Judge.

The Tax Court held that the Commissioner of Internal Revenue rightly included in the gross income of the petitioner, Walter G. Hougland, Jr., all the income for the year 1940 from a partnership arrangement between petitioner and his mother and his wife.

The record shows that the petitioner, by means of the financial assistance of his father by whom he was employed, purchased a towboat for $158,000; and, under the name “Hougland’s,” engaged profitably in river transportation. In August 1939, about two years after his purchase of the towboat, petitioner sold a one-half…