Greenberger v. Commissioner of Internal Revenue

MAJOR, Chief Judge.

This petition is .to review a decision and order of the Tax Court of the United States, rendered and entered' June 4, 1948, •sustaining the determination of the Commissioner of Internal Revenue that there were deficiencies in petitioner’s income tax for the calendar year 1943, in the amount of $85,527.19, and for the calendar year 1944, in the amount of $100,547.32.

The sole question for decision is whether the petitioner was taxable under Sec. 22(a) of the Internal Revenue Code, 26 U.S.C.A. § 22(a), on the income of a partnership business or whether there was a valid family…