United States Board of Tax Appeals December 28, 1927, Docket No. 6435. (Staley v. Commissioner)

lead-opinion

*934OPINION.

Phillips:

The pleadings present two questions for decision: (1) The extent to which income was received by petitioner upon the organization of a corporation to take over the assets of a partnership, and (2) whether the respondent properly asserts against the petitioner a deficiency determined upon the income of his wife.