Forman v. Commissioner of Internal Revenue

HARRISON, District Judge.

This is a petition to review a decision of the Tax Court which determined that no partnership existed between petitioner and his wife for income tax purposes during the year 1945. The deficiency amounted to $18,983.55.

The record discloses that on October 1, 1941, petitioner married his present wife, Marion. She had about $14,000, the proceeds of an insurance policy on the life of her deceased former husband.

Prior to 1940, the petitioner was employed by his brother, William Forman, as manager of a theatre at a salary of $50 or $60 per week.

At the time of said marriage,…