Dwight A. Ward v. Commissioner of Internal Revenue, Hanna P. Ward v. Commissioner of Internal Revenue

Before us are the petitions of Dwight A. Ward and Hanna P. Ward to review decisions of the Tax Court entered on August 13, 1953, 20 T.C. 332 decreeing that there were deficiencies in the petitioners’ income taxes for the year 1946 in the respective amounts of $8051.46 and $2444.45. The determination of the Tax Court was made on petitions from a determination of the Commissioner of Internal Revenue finding deficiencies in the respective amounts of $11,221.46 and $1,965.95.

Petitioners are husband and wife, the wife’s case being here-merely because of her community interest under California law. Throughout the proceeding the record in the husband’s case was used as that in the wife’s case, because this controversy arose out of the business carried on by the husband as one of the partners in a commercial enterprise.

The reference to “taxpayer” will mean petitioner Dwight A. Ward.

For many years prior to November 1, 1945, taxpayer was an equal partner with his two brothers Harry Ward and D. T. Ward in a partnership which conducted the business of manufacturing refrigerators under the name of “Ward Refrigerator & Mfg. Co.”, at Los Angeles, California. Because of disputes as to the…