Middlebrook v. Commissioner

OPINION.

Black, Judge:

The principal issue in this proceeding is whether Virginia D. Middlebrook, petitioner’s wife, should be recognized in the taxable years 1941 to 1945 as a partner with her husband, the petitioner, and Harry E. Brown in a partnership doing business as Metropolitan Buick Co. Respondent does not dispute that the Metropolitan Buick Co. was operated as a partnership during the taxable years here in question and he has recognized petitioner and Harry E. Brown as partners, but has refused to give recognition to Virginia as a partner and has taxed her interest in the partnership…