Brackman v. Commissioner

*261OPINION.

Matthews :

The sole issue presented in this proceeding is whether the petitioner and his wife were partners so that only one-half of the income derived from the business conducted by them jointly is taxable to the petitioner. The petitioner’s wife from the time they were married always assisted in the business and gave him advice as to what investments to make. They orally agreed to share the profits and .losses equally. The profits were not distributed to them, but were invested in real estate, which was taken in their joint names.

Stevenson, who was credit manager of a company which…