Wilson v. Commissioner of Internal Revenue

EVANS, Circuit Judge.

The Tax Court determined that a partnership for income tax purposes did not exist between taxpayer and his wife, for the year 1941. A tax deficiency of $1,596.89 was thereupon entered against petitioner.

The facts are not seriously controverted. The inferences to be drawn from the undisputed facts furnish the basis of the possible dispute. The facts, briefly stated, are:

David Wilson had been in a co-partnership with his brother, conducting a rendering business. This partnership failed.

Mary, the wife, was thrifty and industrious. She worked at a furniture factory five days…