Greta Ann Clifton - Page 6

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          (truck), and a 1985 Ford Mustang.  Petitioner further testified             
          that the 1965 Mustang and the truck were used partially for                 
          business use and partially for personal use, while the 1985                 
          Mustang was used exclusively for personal use.  The truck was               
          purchased by petitioner in May of 1985.  Petitioner purchased the           
          truck for $3,330, paying with two separate checks drawn on the              
          Orad account.  The 1985 Mustang was purchased by petitioner on              
          June 12, 1985, with a down payment in the amount of $7,000, paid            
          with a check drawn on the Orad account.  During 1985, petitioner            
          sold her 1985 Mustang.                                                      
          Issue 1. Unreported Schedule C Income                                       
               Respondent determined that all of the income derived by Orad           
          should be included in petitioner's return.  Petitioner asserts              
          that Orad was a partnership; thus, only one-half of the income              
          from Orad is taxable to her.                                                
               As a general rule, the Commissioner's determinations are               
          afforded a presumption of correctness, and the taxpayer bears the           
          burden of proving that those determinations are erroneous.  Rule            
          142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).                       
               A partnership is broadly defined as "a syndicate, group,               
          pool, joint venture, or other unincorporated organization,                  
          through or by means of which any business, financial operation,             
          or venture is carried on".  Sec. 7701(a)(2); sec. 1.761-1(a),               
          Income Tax Regs.  Generally, a partnership exists when persons              

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