Roughan v. Commissioner of Internal Revenue

DOBIE, Circuit Judge.

This is an appeal from a decision of the Tax Court of the United States sustaining a deficiency assessment against the taxpayer on income taxes alleged to be due for the years 1944 and 1945 in the respective amounts of $218,762.80 and $63,816.75. This deficiency was 'based on the Commissioner’s refusal to recognize the taxpayer’s parents, wife, and son as partners for federal income tax purposes during the years in question. The Commissioner included all the business income of the partnership in 1944 and 1945 in the taxpayer’s gross income, and the Tax Court upheld this…