Hamilton v. Commissioner

ANDERSON, Circuit Judge.

This is a petition for a review of a decision of the Board of Tax Appeals, holding the petitioner liable for $11,378.15 as a deficiency in his income tax for 1922.

The question is whether the petitioner is taxable for the entire income from the business then conducted by him, or whether one-fourth, or $20,703.66, is the income of his wife. The facts appear in the depositions of the petitioner and his wife; there was no-other evidence.

In 1907, petitioner’s wife (then Helen Wade) inherited from her father a shoe-trimming plant and business in Brockton, Mass., consisting…