Canfield v. Commissioner of Internal Revenue

MARTIN, Circuit Judge.

On this petition for review, the taxpayer insists that the Tax Court erred in deciding that there is a deficiency due in his income tax for 1941 in the amount of $4,121.06, or in any other amount. The case presents the issue whether a husband and wife partnership agreement executed in writing on October 10, 1941, should be recognized for tax purposes as a partnership. The Tax Court, in the opinion of the majority, stated that the arrangement between petitioner and his wife seems to fall within the broad scope of the definition of the term “partnership” in Section 3797 of…