United States Tax Court September 27, 1949, Docket No. 17505 (Harmon v. Commissioner)

lead-opinion

OPINION.

Harlan, Judge:

The first issue is whether Gladys M. Harmon, petitioner’s wife, and Jack D. Harmon, petitioner’s son, should be recognized for income tax purposes as his partners for the taxable years 1943 and 1944.

We have found as a fact that the partnership here in question was formed July 1,1942, with no intent on the part of Gladys M.