Isidore Brown and Gladys J. Brown v. Commissioner of Internal Revenue

MAJOR, Circuit Judge.

This is a petition for review of a decision of the Tax Court of the United States, sustaining deficiencies in the income taxes of petitioner, Gladys J. Brown, for the years 1948 and 1949, respectively. 22 T.C. 147. Petitioners Isidore Brown and Gladys J. Brown, husband and wife, filed joint returns for those years, hence are joined as petitioners. This controversy, however, relates only to the asserted income of Gladys J. Brown, who will subsequently be referred to as the taxpayer.

Taxpayer was, from October 24, 1945, to September 30, 1950, the sole owner of a business…