Income accrual to association of persons depends on factual ownership of contractual work and risk; no tax liability arose.

No income accrued to the Association of Persons where the contractual work was to be performed by the constituents in their individual capacities and at their own risk, so any income, if generated, accrued to the respective constituents instead. The Tribunal's finding rested on accepted factual material and the matter turned on its peculiar facts. On that basis, the Association of Persons was not liable to tax on the income in question, and no substantial question of law arose for determination.

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Issues: Whether, on the facts found, any income accrued to the Association of Persons so as to render it liable to tax, and whether any substantial question of law arose for consideration in the appeals.

Analysis: The Tribunal's finding that no income accrued to the Association of Persons was based on the factual position that the contractual work was to be performed by the constituents in their individual capacities and at their own risk, so that the income, if any, would accrue to the respective constituents and not to the Association of Persons. The factual foundation for this view was accepted, and the matter was treated as turning on its peculiar facts.

Conclusion: The Association of Persons was not liable to be taxed on the income in question, and no substantial question of law arose for determination.

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