Stoumen v. Commissioner of Internal Revenue

STALEY, Circuit Judge.

This is a petition for review of a decision of the Tax Court which sustained the Commissioner’s deficiency assessments in petitioner’s income taxes for the years 1943, 1944, and 1945. 1

Petitioner, Bernard Stoumen, and his brother Abraham were equal partners in the firm Fairplay Knitting Mills, engaged in the manufacture and jobbing of knit goods. During the times which concern us. here, petitioner’s principal duties consisted of expediting shipments to the firm and working in the shipping end of the business. He did not handle the books and knew nothing of their details,…