Simmons v. Commissioner of Internal Revenue

LEE, Circuit Judge.

This case is before us on four petitions for review of decisions of the Tax Court, and each involves petitioner’s income-tax liability for the year 1943. The question posed by each petition is whether the petitioner is taxable with the income accruing to his wife during the taxable year from two partnerships known as Simmons Brothers and Simmons Company, in each of which petitioner’s wife was a partner. The issue in each petition being the same, the four petitions were consolidated by order of this Court for argument and decision. The statutes involved are set forth in the…