Leonard A. Farris and Katherine Farris v. Commissioner of Internal Revenue

HUXMAN, Circuit Judge.

The question presented by this appeal is whether in 1948 the petitioner, Leonard A. Farris, received ordinary income in the amount of $12,500 in connection with the liquidation of a partnership of which he was a member. Petitioner, Katherine Farris, is the wife of Leonard A. Farris and, as such, joined in the joint tax return. Further reference to her will not be necessary herein. The collector’s determination that Farris received ordinary income in the amount above stated was on petition for redetermination affirmed by the tax court and this appeal challenges the…