Scott v. Self, Acting Collector of Internal Revenue

GARDNER, Chief Judge.

This appeal is from a judgment of dismissal of an action brought by appellant against W. D. Self, Acting Collector of Internal Revenue for the District of Arkansas, to recover certain federal income taxes alleged to have been erroneously assessed and collected. The taxes for the recovery of which the action was brought were assessed against appellant for the taxable year 1943. The taxpayer alleged that the income involved was the income of a partnership composed of himself and his wife, Juliette B. Scott, whereas the Collector contended that no valid partnership _ existed…